US Resident Consultant Working Part-Time in Canada for

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QUESTION:
I am a Canadian citizen but US Green Card holder for many years,
resident in the US.  I am doing P/T consulting work and may have
an opportunity to do some work in Canada (Part-time).  My
contract is with a US consulting firm (as a contractor, not an
employee).  I would be paid in the US.  How does the Canadian tax
system treat this situation?  As a Canadian citizen I presume
there is no work visa issue?
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david ingram replies:
If you are a US resident and you are coming across the border to
do a bit of work as a self employed person and have no fixed base
of operation in Canada, your earnings are exempt from Canadian
Tax under Article XIV of the US / Canada Income Tax Convention as
follows:
ARTICLE XIV
Independent Personal Services
Income derived by an individual who is a resident of a
Contracting State in respect of independent personal services may
be taxed in that State. Such income may also be taxed in the
other Contracting State if the individual has or had a fixed base
regularly available to him in that other State but only to the
extent that the income is attributable to the fixed base.
If you have a fixed base in Canada, then you will be taxable in
Canada first on the money earned in Canada.  You would then claim
the tax paid to Canada as a credit on form 1116 with your US 1040
return
Answers to this and other similar  questions can be obtained free
on Air every Sunday morning. Call (604) 280-0600.
Starting this Sunday at 9:00 AM on 600AM in Vancouver, Fred
Snyder of Cartier Partners and I, David Ingram  will be hosting
an INFOMERCIAL but LIVE talk show called "ITS YOUR MONEY"
Those outside of the Lower Mainland will be able to listen on the
internet at
www.600AM.com
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