This is for all those individuals and corporations with representatives that are not permanently living in the US but are working in the US temporarily or snowbirding.
A number of filing situations are triggered once an individual has spent more than 183 days in the US. Not every person is affected by this but some have delicate situations that are dependent on spending less than 183 days in the US (for example, FBAR filings, creating a Permanent Establishment etc.).
This week the IRS released guidance for situations where COVID prevents an individual from returning to their home country. Simply put, an individual will be able to exempt up to 60 days of presence in the US beginning at any date between February 1st and April 1st.
Here is the link to the announcement COVID and Days of Presence in the US
Time is required to properly digest the complex US proposals (after all, the US Treasury itself has not yet released regulations), but it will be very important for our government to acknowledge the proposals’ impact on Canada and to indicate a path forward. Canada has many advantages. Perhaps we have relied too much, for too many years, on our competitive tax rate relative to the United States’. Now that we no longer enjoy the tax rate advantage, a new course needs to be plotted.