It has been confirmed that a Chinese citizen attempting to buy Hudson's Bay does not pay income tax.Ruby Liu is a member of the Chinese Communist Party's (CCP) business organizations, owns three large malls and a golf course in BC, and openly admits to furthering the party's interests. The Vancouver Sun says Liu, also known as the “Vancouver-based billionaire," plans to turn some of her real estate holdings into market housing.Liu has recently launched court proceedings to buy the Hudson's Bay Company, hoping to purchase 25 of its stores currently under bankruptcy protection.She's willing to pay $469 million, while landlords are currently opposing the offer. .Supreme Court documents confirmed by journalist Bob Mackin, show Liu is not a Canadian citizen but a permanent resident holding Chinese citizenship.China does not allow dual citizenship.The courts do not mention Liu's immigration status, and although Liu owns a mansion in Vancouver, her address is listed as "20 Yinggu Villa, Shenzhen, Guangdong, China."The document asks whether Liu is a "resident of Canada for income tax purposes."Liu ticked off the box "No.".The Canada Revenue Agency (CRA) states, "Under the Canadian income tax system, an individual's liability for income tax is based on his or her status as a resident or a non-resident of Canada.""Generally, an individual is subject to provincial tax on his or her worldwide income from all sources if the individual is resident in a particular province on December 31 of the particular tax year. An individual is considered to be resident in the province where he or she has significant residential ties."Significant residential ties are defined by the CRA as a "dwelling place (or places); spouse or common-law partner; and dependants."In terms of dwelling places this means, "Where an individual who leaves Canada keeps a dwelling place in Canada (whether owned or leased), available for his or her occupation, that dwelling place will be considered to be a significant residential tie with Canada during the individual's stay abroad.".“A non-resident individual is only subject to Canadian income tax on income from sources within Canada,” the CRA said to the Vancouver Sun. However, they say Canada has tax treaties that prevent "double taxation."In certain cases, when an individual is a resident of another country, “these provisions are known as the ‘tie-breaker rules', therefore not deemed to be a resident of Canada.”Liu's Ontario Supreme Court case to buy Hudson's Bay stores has yet to be decided.
