Reg. 2602(1)
Administrative Policy
8 October 2014 Memorandum 2014-0539571I7 - NL tax vs Non-Res Surtax
Is employment income earned by a non-resident individual working in the Newfoundland offshore area (NOA) subject to provincial tax or the surtax in s. 120(1)? CRA stated:
[E]mployment income earned by the non-resident employees in the NOA is not income earned in the year in a province. Therefore, the income is subject to the surtax in subsection 120(1) and is not subject to NL provincial tax.
13 June 2012 T.I. 2012-0440381E5 -
Where a US-resident hockey player plays for a team that has a permanent establishment only in Ontario but he performs his duties of employment in part at arenas in other provinces, Reg. 2602 will require that his employment income be allocated in accordance with the duties performed in each province. The allocation would be required to be on a reasonable basis.