4 Institutional and Other Initiatives
As part of the overall scheme to attract international shipping operations to Canada,
the Canadian government and, in particular, the Province of British Columbia also
set about various initiatives to encourage and facilitate the movement of international
shipping operations to Canada. Perhaps chief among these initiatives was and is the
funding of the Vancouver International Maritime Centre whose stated purpose is to
promote, foster and encourage the development of Vancouver, British Columbia as a
location for the ownership, central control and management of international shipping
Subsection (6.03) applies to a corporation, trust or partnership (in this subsection and
subsection (6.03) referred to as the “relevant entity”) for a taxation year if
(a) the relevant entity does not satisfy the condition in subparagraph (6)(a)(i), determined
without reference to subsection (6.03);
(b) all or substantially all the gross revenue of the relevant entity for the year consists of any
one or more of
(i) gross revenue from the provision of services to one or more eligible entities, other
than services described in any of paragraphs (a) to (h) of the definition “international shipping” in subsection 248(1),
(ii) gross revenue from international shipping,
(iii) gross revenue from an eligible interest held by it in an eligible entity, and
(iv) interest on a debt owing by an eligible entity in which an eligible interest is held by
it or a person related to it;
(c) either the relevant entity is a subsidiary wholly-owned corporation (as defined in
subsection 87(1.4)) of the eligible entity referred to in paragraph (b) or an eligible
interest in each eligible entity referred to in paragraph (b) is held throughout the year by
(i) the relevant entity,
(ii) one or more persons related to the relevant entity (if the relevant entity and each
such person is a corporation), or persons or partnerships affiliated with the relevant
entity (in any other case), or
(iii) any combination of the relevant entity and persons or partnerships described in
subparagraph (ii); and
(d) all or substantially all the shares of the capital stock of, or interests in, the relevant entity
are held, directly or indirectly through one or more subsidiary wholly-owned corporations (as defined in subsection 87(1.4)), throughout the year by one or more corporations, trusts or partnerships that would be eligible entities if they did not own shares of,
or interests in, the relevant entity.
250(6.03) Service providers
If this subsection applies for a taxation year, then for the purposes of subsection (6) and
paragraph 81(1)(c),
(a) the relevant entity is deemed to have international shipping as its principal business in
the year; and
(b) the gross revenue described in subparagraph (6.02) (b)(i) is deemed to be gross revenue
from international shipping.
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F. M. Manolis and R. L. Bozzer
As part of the overall scheme to attract international shipping operations to Canada,
the Canadian government and, in particular, the Province of British Columbia also
set about various initiatives to encourage and facilitate the movement of international
shipping operations to Canada. Perhaps chief among these initiatives was and is the
funding of the Vancouver International Maritime Centre whose stated purpose is to
promote, foster and encourage the development of Vancouver, British Columbia as a
location for the ownership, central control and management of international shipping
Subsection (6.03) applies to a corporation, trust or partnership (in this subsection and
subsection (6.03) referred to as the “relevant entity”) for a taxation year if
(a) the relevant entity does not satisfy the condition in subparagraph (6)(a)(i), determined
without reference to subsection (6.03);
(b) all or substantially all the gross revenue of the relevant entity for the year consists of any
one or more of
(i) gross revenue from the provision of services to one or more eligible entities, other
than services described in any of paragraphs (a) to (h) of the definition “international shipping” in subsection 248(1),
(ii) gross revenue from international shipping,
(iii) gross revenue from an eligible interest held by it in an eligible entity, and
(iv) interest on a debt owing by an eligible entity in which an eligible interest is held by
it or a person related to it;
(c) either the relevant entity is a subsidiary wholly-owned corporation (as defined in
subsection 87(1.4)) of the eligible entity referred to in paragraph (b) or an eligible
interest in each eligible entity referred to in paragraph (b) is held throughout the year by
(i) the relevant entity,
(ii) one or more persons related to the relevant entity (if the relevant entity and each
such person is a corporation), or persons or partnerships affiliated with the relevant
entity (in any other case), or
(iii) any combination of the relevant entity and persons or partnerships described in
subparagraph (ii); and
(d) all or substantially all the shares of the capital stock of, or interests in, the relevant entity
are held, directly or indirectly through one or more subsidiary wholly-owned corporations (as defined in subsection 87(1.4)), throughout the year by one or more corporations, trusts or partnerships that would be eligible entities if they did not own shares of,
or interests in, the relevant entity.
250(6.03) Service providers
If this subsection applies for a taxation year, then for the purposes of subsection (6) and
paragraph 81(1)(c),
(a) the relevant entity is deemed to have international shipping as its principal business in
the year; and
(b) the gross revenue described in subparagraph (6.02) (b)(i) is deemed to be gross revenue
from international shipping.
466
F. M. Manolis and R. L. Bozzer