RC has acknowledged that where a non-resident director participates in a meeting held by teleconference call, his fees are not income from duties performed inside Canada.
Summary Under
Tax Topics - Income Tax Regulations - Regulation 101Revenue Canada has conceded that the flat rate of 15% of gross may be applied to the fees of a non-resident director who attends meetings in Canada. Although the U.S. Convention may relieve the director of any ultimate Canadian tax liability, RC normally insists that deductions at source be withheld by the employer and that the employee apply for a refund upon filing a return.
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