Personal ServicesA U.S. citizen or resident who is temporarily present in Canadaduring the tax year is exempt from Canadian income taxes on pay forservices performed, or remittances received from the United States, ifthe citizen or resident qualifies under one of the treaty exemptionprovisions set out below. Compensation for personal services (Articles XIV, XV, andXVI).Under the treaty, the exemption from Canadian tax for personalservice income of a U.S. resident depends on whether the services areperformed as an employee (dependent personal services) or as anindependent contractor or self-employed individual (independentpersonal services). Income U.S. residents receive for the performance of independentpersonal services in Canada (except as public entertainers) is exemptfrom Canadian tax if they do not have (or have not had) a fixed baseregularly available to them in Canada for the purpose of performingthe services. If the U.S. residents have (or had) a fixed baseavailable in Canada, under the treaty they are taxed by Canada only onthe income attributable to the fixed base. Income U.S. residents receive for the performance of dependentpersonal services in Canada (except as public entertainers) is exemptfrom Canadian tax if it is not more than $10,000 in Canadian currencyfor the year. If it is more than $10,000 for the year, it is exemptonly if: - The residents are present in Canada for no more than 183days during the calendar year, and
- The income is not borne by a Canadian resident employer orby a permanent establishment or fixed base of an employer inCanada.
For example, assume that you are a U.S. resident employed under an8-month contract with a Canadian firm to install equipment in theirMontreal plant. During the calendar year you were physically presentin Canada for 179 days and were paid $10,120 (Canadian) for yourservices. Although you were in Canada for not more than 183 daysduring the year, your income is not exempt from Canadian income taxbecause it was borne by a Canadian employer and was morethan $10,000 (Canadian) for the year. Pay received by a U.S. resident for work regularly done in morethan one country as an employee on a ship, aircraft, motor vehicle, ortrain operated by a U.S. resident is exempt from Canadian tax. Public entertainers.The exemptions for either dependent or independent personalservices do not apply to public entertainers (such as theater, motionpicture, radio, or television artistes, musicians, or athletes) fromthe United States who derive more than $15,000 in gross receipts inCanadian currency, including reimbursed expenses, from theirentertainment activities in Canada during the calendar year. However,the exemptions do apply, regardless of this $15,000 limit, to athletesparticipating in team sports in leagues with regularly scheduled gamesin both the United States and Canada. Compensation paid by the U.S. Government (Article XIX).Wages, salaries, and similar income (other than pensions) paid to aU.S. citizen by the United States or any of its agencies,instrumentalities, or political subdivisions for discharginggovernmental functions are exempt from Canadian income tax. Milan cheap hotelsThe exemption does not apply to pay for services performed inconnection with any trade or business carried on for profit by theUnited States, or any of its agencies, instrumentalities, or politicalsubdivisions. Students and apprentices (Article XX).A full-time student, apprentice, or business trainee who is inCanada to study or acquire business experience is exempt from Canadianincome tax on remittances received from any source outside Canada formaintenance, education, or training. The recipient must be or musthave been a U.S. resident immediately before visiting Canada. |