In which of the following cases would the interest payment made to a non-resident be subject to Part XIII withholding tax?
A) Ling, a resident of a country that does not have a tax treaty with Canada, earns interest of $5,000 from a Canadian term deposit.
B) Jin, a resident of a country that does not have a tax treaty with Canada, earns interest of $15,000 on a Canadian government bond.
C) Dou, a U.S. resident, earns interest of $42,000 on a loan to Moon Limited, a CCPC. Dou owns 51% of the shares in the company.
D) Ying, a resident of a country that does not have a tax treaty with Canada, earns $25,000 on a loan to Sun Enterprises Limited, a CCPC. Ying owns 40% of the shares in the company.
Correct Answer:
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