CRA on Cross Border Secondment

In 2013-0508651E5, the CRA considered a situation where Canco hired USco to provide services and equipment in Canada. The CRA opined that even if the employees who are providing services to Canco remain on the payroll of USco, Canco could be liable for the withholding and remitting of source deductions and reporting of those amounts for the employees. The main question is whether employer/employee relationship exists between Canco and the USco employees.

Prepared by: Ken Jiang

Ken Jiang is a partner at the firm’s Vancouver office. His practice focuses on corporate and personal tax planning, international tax planning and representation of taxpayers in disputes with Canada Revenue Agency. Ken is fluent and proficient in Chinese (Mandarin).… more »