2024-10-01
Today we published a chart of Rev. Rul. 76-19. In this ruling, a Canadian corporation sent two employees to the U.S. for 12 months of training. The employees continued to be paid by the Canadian employer. The ruling held that:
This ruling was published prior to Canada and the U.S. entering into a totalization agreement. The totalization agreement would likely change holding number five.
It is interesting that the ruling did not discuss whether the Canadian employer itself could be engaged in a U.S. trade or business.