US Citizen Working in Canada

[vondrlm]

Not a new subject, but one that we are struggling with from a taxation standpoint. I need advice on the following situation.

* Our empolyeer is an investor in a Canadian industrial project under construction.
* To support the local contractors, I and some others, were asked to travel from the US to Canada to support and advise the local contractors on the technical side of the project.
* In general, we spend 14-28 days a month working in Canada and the balance either working or commuting back to the US.
* Our overall days "in country" will be less than 183 for some and more than 183 for others accross a continous 365 day period.
* In no case should anyone be there more than one year.
* We continue to draw our US income and pay taxes (FICA, FIT and State) as usual.
* We are on expenses (hotels and meals) to live on in Canada as business travelers.

My question is if we have or will trigger any Canadian tax liability under the above circumstances?

[nelsona]

It would not in the past, but with the change to the treaty coming into effect, merely having a relationship for so long, and being in canada may be enough to trigger Cdn tax.