With regard to Canadian sourced income and the definition of "permanent establishment": (a) why is working from home in Canada while logging into US-based companies' internet servers interpreted or considered as Canadian-sourced income by the Canada Revenue Agency (CRA); (b) is the CRA considering a commuter's home as a US company's permanent establishment or as the commuter's permanent establishment; (c) since the commuter's home is not US company property by any measurement, why does the CRA consider the commuter’s home as a US company’s permanent establishment or as the commuter’s permanent establishment of work and in turn how does neither case imply that the commuter and his home are therefore a small business entity generating Canadian-sourced income with deductible expenses; (d) if a commuter's home is considered a commuter's permanent establishment and the commuter is not employed by a Canadian company but provides services to a foreign company, why is the commuter not considered its own small business entity for Canadian tax purposes and not qualified for small business tax deductions; (e) if the commuter’s home is considered as a permanent establishment, why are commuter business expenses such as utilities, travel, rent, vehicle used and registration, etc. not allowed to be deducted as business expenses from their Canadian-sourced income; and (f) if a commuter’s home is considered a permanent establishment, why is going to another office from the commuter's home permanent establishment not considered as a business travel expense?
In the House of Commons on March 20th, 2023. See this statement in context.