agent

By services, 28 November, 2015

The taxpayer (which was engaged in fishing for shrimp in Canadian waters) was found, based on the wording of an agreement between it and a non-resident group ("Uhrenholt") to have sold the shrimp harvested by it overseas through Uhrenholt as its agent rather than immediately upon landing, with the result that a portion of the interest credited by the taxpayer to Uhrenholt qualified for exemption under s.