US (Likewise, U.S. citizens working and living in Canada under a work permit pursuant to CUSMA (as USMCA is referred to by Canadian authorities) are also subject to corresponding income tax liabilities and end-of-year filing of tax returns in Canada.) In general, there can be income tax liabilities in accordance to where the employee works regardless of where legal or physical residence is maintained during employment. This is much like U.S. citizens who live in one state but work in another who are then subject to state income and other taxes in the state in which they work. If their legal residence is still in their home country, workers may also be required to file a return in their home country. Based on income tax treaties, credit is normally available in the home country for income and other payroll taxes paid in the foreign country. Bilateral treaties exist to allow workers to regain benefits. For example, after a minimum of 1.5 years of work in the U.S., workers become eligible for a pro-rata Social Security benefit under what is known in the U.S. as a totalization agreement. After more than 10 years of work in the U.S., the regular Social Security benefit calculation minus the Windfall Elimination Provision will be applied. Therefore, the worker may receive 3 cheques, one each from the Canada Pension Plan, Old Age Security, and U.S. Social Security. Comparison to H-1B visa TN status has some similarities with the H-1B visa. TN status may be easier for some Canadians or Mexicans to obtain, as they are not subject to the annual cap for H-1B visas issued. But the most important difference is that TN status does not include the doctrine of dual intent. Therefore, Canadians or Mexicans on TN status must be careful if they desire to ultimately pursue the green card. Either they should first switch to the H-1B visa before applying for the green card, or they must carefully time things to ensure they do not attempt to renew TN status after the green card application is formally pending (generally meaning that Form I-485 package has been filed for TN holder; those pursuing consular process can renew until just before the interview appointment at an immigrant-visa–issuing U.S. consulate). Employer requirements Employers do not need to maintain extensive documents and records on TN workers, unlike with H-1B employees. In the case of an investigation or