Alpine tech (at) is a company incorporated in Switzerland. at develops custom software for public infrastructure projects
Question:
Alpine tech (“at”) is a company incorporated in Switzerland. at develops custom software for public infrastructure projects worldwide. at is owned equally by tom and ingrid, tom is a tax resident of Australia and Ingrid is a tax resident of Switzerland. they are jointly responsible for all of at’s business decisions, which they decide via teleconference from their home countries. tom and ingrid also consult with key clients via teleconference from their home countries, although some critical development meetings require them to travel to their clients’ head-offices in various locations around the world. at sometimes leases serviced offices when meeting with clients overseas. required: with reference to the background information above, determine the residency status of at. you do not need to consider the double tax agreements. explain your answer and cite relevant legislation.
Introduction To Federal Income Taxation In Canada
ISBN: 9781554965021
33rd Edition
Authors: Robert E. Beam, Stanley N. Laiken, James J. Barnett