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us resident with canadian income via t4a-nr
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as per the canada-u.s. tax treaty (the “treaty”), a u.s. corporation carrying on business in canada is only subject to taxation on income earned in canada through a fixed place of business or permanent establishment. therefore, if a u.s. company does not have a permanent establishment (pe) in canada then their canadian source business income is not subject to canadian federal tax. https://www.fin.gc.ca/treaties-conventions/usa_-eng.asp
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