What makes physicians & surgeons different from an ordinary filing?
Physicians moving between systems carry a professional corporation or practice that does not travel with them: the entity remains taxable where it was resident, while the doctor becomes taxable where they now work. An ordinary preparer applies the general rule and stops there, which is how the relief in the specific provision goes unclaimed.
Can you work with my existing accountant?
That is how most of these engagements run. They keep the domestic file, we take the cross-border piece, and the boundary is agreed in writing so nothing is done twice or missed.
Which country taxes my medical professional corporation after I move abroad?
The corporation does not move with you. It stays taxable where it is resident, and a company's residence turns on where it is actually managed and controlled rather than where its shareholder now sleeps. So the usual starting position is that the company keeps filing and paying where it was, while you become taxable personally where you now practise. The complication arrives when you keep making the company's decisions from your new country, because that can give the new country a residence claim of its own and leave the company answering to both. Settle that before it is asked of you.
Do I pay tax twice on locum shifts worked in another country?
Rarely twice over, but you can certainly be taxed in both places before relief is applied. The country where the shifts were physically worked generally has the first claim, because the work was performed there. Your country of residence then taxes your worldwide income and gives relief for what the other country properly charged. The order matters, because relief is given against tax correctly paid. If the source country took more than it was entitled to, the answer is to correct that return rather than to claim the excess as a credit at home.
Is my partnership share from a clinic taxed where the clinic is?
Often, yes. A partnership share is usually treated as income arising where the partnership carries on its business, not where the partner happens to live, which is why doctors who left a clinic behind still receive assessments from the country they moved from. Your country of residence will also want to see the share, with relief for what was charged at source. The practical difficulty is that the two countries may not characterise the partnership the same way, and if one treats it as transparent and the other does not, the relief has to be argued rather than assumed.
Does my professional corporation become resident where I now practise?
It can. Residence for a company follows where the real decisions are made, so a practice company whose sole director now signs everything from another country has a genuine argument against it. Where both countries claim the company, the treaty tie-breaker decides, and that is a process rather than a box to tick. The consequences are not only corporate, because a change in a company's residence can trigger a charge on its assets in the country it is treated as leaving. If you are moving and intend to keep the company, settle this before the move.
How is hospital employment income divided when I work in both countries?
By where the duties were performed, in the first instance. Days worked in one country produce income sourced there, and that is the basis on which employment income is normally split, rather than by where the employer sits or where the money lands. Treaties then provide a narrow exemption for short assignments, subject to conditions about who bears the cost of your employment and how long you are present. Your residence country still taxes the whole, with relief for the other country's share. Keeping a day record while you work is far easier than reconstructing one afterwards.
Which country gives the credit when both tax the same income?
The country where you are resident gives the credit, for tax properly paid to the country of source. Residence is therefore the first thing to settle, and for a doctor mid-move it is often the thing nobody has actually decided — the licensing body, the insurer and the payroll office can each be working on a different assumption. Where both countries consider you resident, the treaty tie-breaker resolves it by looking at your permanent home, your centre of vital interests and where you habitually live. Until that is fixed, credits claimed in either return are provisional.
How do I actually stop being taxed twice?
In this order. Fix your residence under each country's own rules, and if both claim you, apply the treaty tie-breaker. Identify where each type of income is sourced. Read the article that covers that income type, because it decides who taxes and at what maximum rate. Then claim the relief on the residence-country return, with proof of the foreign tax. Most of the tax people lose to double taxation is lost at the last step, not the first. See how double taxation is relieved.
Which countries have a tax treaty with the United States?
Around sixty, including Canada, the United Kingdom, India, Australia and most of western Europe — but the list matters less than the terms, because each treaty caps rates and allocates income differently. Two countries with treaties can produce opposite answers on the same pension or the same royalty. What decides your position is the specific article covering your income type. See our country guides.
