Search found 6 matches

by lightoasis
Tue Jan 21, 2020 10:40 am
Forum: Canada / United States Tax & Accounting
Topic: Would Deferred Commissions Pass Permanent Establishment Test?
Replies: 10
Views: 3712

Re: Would Deferred Commissions Pass Permanent Establishment Test?

I apologize, I wasn't aware that the sale of property affected the question. This is new territory for me which is why I came to the forum. Thank you for taking the time to answer.
by lightoasis
Mon Jan 20, 2020 9:57 pm
Forum: Canada / United States Tax & Accounting
Topic: Would Deferred Commissions Pass Permanent Establishment Test?
Replies: 10
Views: 3712

Re: Would Deferred Commissions Pass Permanent Establishment Test?

Ok, thanks. Last question - does it make a difference if the transactions are related to real estate? I had one person note "Your commission income was earned from the sale of Taxable Canadian Property and further it was earned from your business when you did have a Permanent Establishment in C...
by lightoasis
Mon Jan 20, 2020 1:39 pm
Forum: Canada / United States Tax & Accounting
Topic: Would Deferred Commissions Pass Permanent Establishment Test?
Replies: 10
Views: 3712

Re: Would Deferred Commissions Pass Permanent Establishment Test?

nelsona wrote:
> Then, indeed this would be self-employment income, not subject to tax in
> Canada, once you are non-resident.

How do you think the CRA would view me collecting HST on the commissions and paying those back but then not paying income tax?
by lightoasis
Sun Jan 19, 2020 10:09 am
Forum: Canada / United States Tax & Accounting
Topic: Would Deferred Commissions Pass Permanent Establishment Test?
Replies: 10
Views: 3712

Re: Would Deferred Commissions Pass Permanent Establishment Test?

nelsona wrote:
> Permanent establishment would only apply to self-employment income. This
> sounds like employment income.

No, sorry, it's self-employment income. I am a self-employed sales representative.
by lightoasis
Fri Jan 17, 2020 4:13 pm
Forum: Canada / United States Tax & Accounting
Topic: Would Deferred Commissions Pass Permanent Establishment Test?
Replies: 10
Views: 3712

Re: Would Deferred Commissions Pass Permanent Establishment Test?

nelsona wrote: > This income would be taxable in canads (and US) in the years it is paid to > you. > I don't know what permanent establishment has to do with your questions. As far as I understood the permanent establishment test, if you don't have one in Canada but are receiving income from a Canad...
by lightoasis
Fri Jan 17, 2020 12:58 pm
Forum: Canada / United States Tax & Accounting
Topic: Would Deferred Commissions Pass Permanent Establishment Test?
Replies: 10
Views: 3712

Would Deferred Commissions Pass Permanent Establishment Test?

I work as a sales representative where part of my commissions are often paid out several years later. For example, a sale in 2019 would generate a commission that is paid out in 2023 or 2024. I will be moving to the US this year and severing all ties with Canada besides maintaining a bank account to...