In 2012-0470331E5, the CRA was asked whether a withholding tax exception was available under s. 116 where a non-resident seller holds real estate in Canada as part of the seller’s business inventory. The CRA confirmed that no such exception is found in the text of s. 116. However, the CRA may allow such an exemption on an administrative basis (see IC72-17R6 paragraph 36). The administrative procedure involves the CRA’s local tax services office issuing a “qualified business exemption” letter in advance of the sale. Such a letter would generally relieve the purchaser from any withholding obligation under s. 116(5.3), and would generally require the seller to provide transaction details to the CRA sufficient to meet the information requirements of s. 116(5.2).