In each of the following Cases, determine whether Rawlings Inc., a non-resident U.S. corporation, is taxable in Canada:
Case 1 - Rawlings is the parent company of Delma Ltd., a company incorporated in British Columbia. Rawlings produces and sells small construction equipment, while Delma produces and sells hand tools. Rawlings sells pieces of equipment to Delma, who in turn sells them in Canada.
Case 2 - Rawlings manufactures small construction equipment in the U.S. Rawlings ships pieces of equipment to a warehouse located in Winnipeg that is rented on a seven year lease. Rawlings has employed an individual in Winnipeg to sell the equipment throughout central Canada. The employee is not allowed to conclude contracts without approval by the U.S. office.
Case 3 - Assume the same facts as in Case 2, except that the employee has the authority to conclude contracts on behalf of the employer.
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