CRA ISSUES GUIDANCE ON INTERNATIONAL INCOME TAX ISSUES

The CRA has released guidance on the following international tax issues raised as a result of COVID-19:

• Income Tax Residency

• Carrying on Business in Canada/Permanent Establishment (PE rules)

• Cross-border Employment Income

• Waiver Requests – Payments to Non-residents for Services Provided in Canada

• Disposition of Taxable Canadian Property (TCP) by Non-residents of Canada – Delay in Processing Clearance Certificate

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