Hi. Tricky cross-border question. I am now a non-resident of Canada, having formally exited Canada to become a US resident in 2019. However, I am a self-employed medical doctor (independent contractor) and I only practice in a remote location in northern Canada, so I will continue to perform my medical services exclusively in Canada. That said, the office does not belong to me, it is shared and I don’t own it or pay rent there, but you could say that it’s always available to me to work at and I work exclusively from that office. I was doing research on the Canada / US Treaty, and it would appear (not 100% certain) that based on these facts, I have a PE in Canada and therefore my medical income would be Canadian-source and taxable in Canada? Do you agree or think there’s any position that my income would only be taxable in the USA where I reside? The provincial health board that pays me will NOT be withholding any Canadian income tax from the income I will earn. Do you think I still have an obligation in the future to file Canadian income tax returns in my situation as a non-resident earning potentially Canadian source income?
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