24 December 2015 Internal T.I. 2014-0560831I7 - International shipping -- summary under International Shipping

CRA indicated that the “international shipping” definition, which “introduced what may be considered to be a new requirement that the ships must be ‘owned or leased’ by the relevant taxpayer” can be satisfied by the taxpayer being the charterer under a time charter (provided it had “commercial management” of the ship, i.e., “the ship owner is operating the ship under the Taxpayer’s direction.”)