I worked in Canada for a foreign employer — is that taxable here?
Yes. The test is where the work was physically performed, not who signed the contract, which company runs the payroll, or which bank account received the money. Duties carried out on Canadian soil are Canadian-source employment income, and the party paying for that work is expected to withhold on it. A treaty article may then exempt the income, but that is a second step and it is not automatic. So the starting point is a record of where you actually were and what you did there, because everything after it is argued from that record.
Why did Canada withhold when my employer and my bank are abroad?
Because withholding follows the workdays, not the money. An employer with no Canadian presence can still have a Canadian withholding obligation for the days its employee spends working here, and many payroll departments discover this late, after the first remittance is queried. The fact that the salary never touched a Canadian account does not move the source of the income. If you believe a treaty exempts the days in question, the sequence matters: relief agreed with the tax authority in advance keeps the money in your hands, while the same relief claimed afterwards becomes a refund you wait a year for.
Can a tax treaty exempt my Canadian workdays entirely?
It can, within limits the article itself sets. These articles usually turn on two things: how much time you spent in the country, and how much remuneration was attributable to that time. Stay inside both and the income can be exempt; cross either and the exemption is simply unavailable, however short the assignment felt. That is why the first thing to establish is the arithmetic rather than the argument. Work out the days and the amounts, then decide whether you are applying for relief in advance or filing to recover tax already withheld.
What is a withholding waiver and when should I apply for one?
A waiver is permission, obtained in advance, for the payer to reduce or stop withholding on Canadian workdays because a treaty is expected to exempt them. Its value is entirely in the timing. Granted before the remuneration for those days is settled, it means the exemption is applied at source and there is nothing to reclaim. Left until afterwards, the same exemption still exists but you reach it through a return for the year and a refund that follows in its own time. Applying early is therefore the single decision that changes the cash position most.
Do I still need to file if the treaty exempts my income?
Usually yes, and that surprises people. An exemption applied at source rests on a position, and the tax authority expects to see that position stated in a filing for the year rather than inferred from an employer payroll decision. Where tax was withheld and no relief was agreed in advance, the filing is the only route to the money. Where a waiver was granted, the filing closes the year and shows the days and the remuneration the waiver was based on. Treat the return as part of the exemption, not as an alternative to it.
How do I count Canadian workdays for a short assignment?
Build the count from evidence rather than memory. Flight records, hotel folios, calendar entries, site access logs and the assignment letter between the two employers are the documents that decide these files, and they are far easier to gather in the month of travel than a year later. Count what you did as well as where you were: a day in the country that was genuinely travel or rest is not a working day, and the distinction has to be supportable. Record it as you go and the rest of the analysis becomes arithmetic.
What is a section 217 return and should I file one?
An election available to a non-resident receiving certain Canadian pension and benefit payments. Normally those payments suffer flat withholding and that is the end of it. Under the election you file a Canadian return and are taxed on that income at graduated rates as though resident, which produces a refund of part of the withholding where the graduated result is lower — and no benefit where it is not. It is worth modelling before electing, because the choice is annual. See the section 217 return.
What is the US exit tax and who actually pays it?
How much it is depends on your unrealised gains rather than on a rate, because it is the expatriation regime rather than a fee. A citizen who gives up citizenship, or a long-term permanent resident whose status ends, is tested against three conditions; meet any one and you are a covered expatriate, treated as having sold your worldwide assets the day before you left, with an exclusion for a slice of the resulting net gain — $890,000 for 2025. Deferred compensation, retirement accounts and interests in trusts are handled under separate rules rather than the deemed sale. Form 8854 reports it. See Form 8854.
