CRA has updated (2012-03-06) the T2SCH91 Information Concerning Claims for Treaty-Based Exemptions (2008 and later tax years).
This form is for non-resident corporations that
• carried on a treaty-protected business in Canada, or
• disposed of Taxable Canadian Property (TCP) that was treaty protected
This is an information form and needs to be filed when you file your corporate T2.
Treaty-protected refers to income or gains on TCP that would normally be required to pay tax in Canada but, because of a treaty, are not required to do so.
Whether or not your business, or TCP disposal, is treaty protected depends on the facts in each individual case and on the treaty itself.