determine how the rental payments made to nonresidents will be taxed by Canada.

In each of the following Cases, determine how the rental payments made to nonresidents will be taxed by Canada. In addition, indicate whether an election to pay Part I tax is available and whether the election would be desirable.

Case 1 Rentco is a U.S. corporation with worldwide rental facilities dedicated to various equipment rentals. Rentco has offices in Saskatchewan, where it rents out farming equipment. Case 2 In 2017, Jack Foster, a U.S. resident, acquired a hunting and fishing lodge in northern Ontario that he rents out. In 2020, he rented the lodge to Canadian residents exclusively. Jack received $42,000 in gross rents and estimates that expenses, including CCA, totaled $14,000. Case 3 Assume the same facts as in Case 2, with one additional consideration. Jack acquired three motor boats in 2018, which he rented to guests of the lodge. In 2020, he received $8,000 in gross boat rents and estimates boat related expenses of $7,000.

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