In 2014-0550611R3 (recently released), a US subsidiary (Forco) of a US non-profit organization (Foreign Parent) had a single employee resident in Canada (Employee) working from the Employee’s home. The Employee’s job was to communicate with Foreign Parent's existing Canadian members and to identify potential new Canadian members. The Employee could not negotiate or conclude contracts. Forco would pay the Employee’s computer costs and would reimburse the Employee’s travel expenses, but Forco would not assume or cover any of the Employee’s home office costs. The home office would not be associated or identified with the business of Forco or Foreign Parent, nor would Forco have access to, or control over, the home office at any time. Although Forco was clearly “carrying on its business in Canada” (see paragraph 7), the CRA ruled that Forco would not be carrying on that business “through a permanent establishment…situated in Canada” within the meaning of Article V of the Canada-US tax treaty (see Ruling A on page 10).