Based solely on the information given in each of the following independent situations, determine, from the choices given below, the most appropriate residency status for each of the following corporations for the current year. (Note: If applicable, assume that none of the corporations obtained articles of continuance following its departure from, or transfer of operations to, Canada.)
(a) Resident for the year, pursuant to ITA 250(4)(a),incorporated in Canada after April 26,1965
(b) Resident for the year, pursuant to ITA 250(4)(b),incorporated in Canada before April 9,1959
(c) Resident for the year, pursuant to ITA 250(4)(c),incorporated in Canada before April 26,1965, and resident or conducte business in Canada
(d) Resident for part of the year, and non-resident for the remainder of the year
(e) Resident because the central management and control of the corporation is exercised in Canada
(f) Non-resident, taxed in Canada on its taxable income earned in Canada and the ITA 219 branch tax
(g) Non-resident for the year
(h) None of the above
1. KK Company was incorporated in Australia in 1983. In 1997, management transferred all operations to Vancouver, where it has operated since. The board of directors has met in Vancouver since the transfer of operations.
2. Corporation CC was incorporated in 1963 in Missouri. As the directors are residents of Manitoba, all board meetings have been held in Winnipeg since incorporation. All operations are conducted in Missouri.
3. LL Company, a Kentucky corporation, operates a portion of its operations in Newfoundland. All employees in Newfoundland are Canadians, except for the managing director. The corporation maintains an inventory in Newfoundland, which is used to supply its markets in Atlantic Canada and eastern Quebec.
4. HH Limited, incorporated in New York state in 1968, has a warehouse in Montreal from which it distributes its products to its Canadian customers. All significant management decisions are made in New York.