Providing services in the US

[blairgoates]

Do I understand this correctly...If a Canadian Corporation does business in the U.S and as long as the Canadian corporation does not have any permanent establishment in the U.S or corporate personnel have spent less that 183 in the U.S providing services then the earnings from the U.S are exempt via tax treaty REGARDLESS of the amount ?

If so and a Protective 1120F return is desired is the income\expense reported or not ?

Thanks

[JGCA]

yes , but remember the 183 days is during any 12 month period, on a protective treaty based 1120F you report no amounts only ask for treaty protection.