Income Tax Act — I-3.3 115
nt by actor’s corporation (2.2) Where a corporation is liable to tax under subsection 212(5.1) in respect of a corporation payment (within the meaning assigned by subsection 212(5.2)) made in a taxation year in respect of an actor and, in a subsequent year, the corporation makes an actor payment (within the meaning assigned by subsection 212(5.2)) to or for the benefit of the actor, the amount of the actor payment is not deductible in computing the income of the corporation for any taxation year and is not included in computing the taxable income earned in Canada of the actor for any taxation year. Non-resident persons  —  2010 Olympic and Paralympic Winter Games (2.3) Notwithstanding subsection (1), no amount is to be included in computing the taxable income earned in Canada for any taxation year of a non-resident person, in respect of any amount paid or payable to that person in respect of activities performed in Canada by that person in connection with the 2010 Olympic Winter Games or the 2010 Paralympic Winter Games, after 2009 and before April 2010, if that person is (a) an athlete who represents a country other than Canada; (b) a member of an officially registered support staff associated with a team from a country other than Canada; (c) a person who serves as a games official; (d) the International Olympic Committee; (e) the International Paralympic Committee; (f) an international sports federation that is a member of the General Association of International Sports Federations; (g) an accredited foreign media organization; or (h) an individual, other than a trust, who is an employee, an officer or a member of a person described in any one or more of paragraphs (a) to (g), or who provides services under contract with one or more persons described in those paragraphs. Non-resident employed as aircraft pilot (3) For the purpose of applying subparagraph (1)(a)(i) to a non-resident person employed as an aircraft pilot, income of the non-resident person that is attributable to a flight (including a leg of a flight) and paid directly or indirectly by a person resident in Canada is attributable to duties performed in Canada in the following proportions: (a) all of the income attributable to the flight if the flight departs from a location in Canada and arrives at a location in Canada; (b) one-half of the income attributable to the flight if the flight departs from a location in Canada and arrives at a location outside Canada; (c) one-half of the income attributable to the flight if the flight departs from a location outside Canada and arrives at a location in Canada; and (d) none of the income attributable to the flight if the flight departs from a location outside Canada and arrives at a location outside Canada. Non-resident’s income from Canadian resource property (4) Where a non-resident person ceases at any particular time in a taxation year to carry on such of the businesses described in any of paragraphs (a) to (g) of the definition principal business corporation in subsection 66(15) as were carried on by the non-resident person immediately before that time at one or more fixed places of business in Canada and either does not commence after that time and during the year to carry on any business so described at a fixed place of business in Canada or disposes of Canadian resource property at any time in the year during which the non-resident person was not carrying on any business so described at a fixed place of business in Canada, the following rules apply: (a) the taxation year of the non-resident person that would otherwise have included the particular time shall be deemed to have ended at that time and a new taxation year shall be deemed to have commenced immediately thereafter; (b) the non-resident person or any partnership of which the non-resident person was a member immediately after the particular time shall be deemed, for the purpose only of computing the non-resident person’s income earned in Canada for the taxa