The residency of an international shipping corporation, under these rules, is determined by.... If you fall within the rules, you're deemed to be not resident in Canada even though you might otherwise be. The determination of where a corporation is resident is often a question of fact, where you look to not just the place of incorporation but rather to where the mind and management of a corporation lie.
If you had a corporation that had been incorporated in another jurisdiction, but that really had its mind and management in Canada, it could, under the common law test for determining residency, be considered resident in Canada. What these rules do is say that if you're a qualifying corporation involved in these qualifying shipping activities and your income and your assets meet the tests in the rule, and you are incorporated outside of Canada, the rules would apply to say that you're deemed to not be a resident of Canada—this corporation.
The policy in general behind our non-resident shipping rules...and these have to be understood in addition to the rules in I think section 81 that say the income of a non-resident corporation carrying on business in Canada, the shipping business, is going to be exempt from Canadian tax if the country of residence where this corporation is resident grants a similar exemption. There's an element of reciprocity in that, and it's also an international norm with Canada and our trading partners.