Non-Resident Corporations (ITA Reg. 412)
Where a corporation is not resident in Canada, "salaries and wages paid in all jurisdictions" by the corporation do not include salaries and wages paid to employees of a permanent establishment outside Canada. When calculating using the general allocation formula under the ITA (Reg. 402(3)(a)), "gross revenue in all jurisdictions" does not include gross revenue reasonably attributable to a permanent establishment outside Canada.
See Also
Guide to Completion of the Alberta Corporate Income Tax Return