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Canadian / HK Tax Question

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  1. #1

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    Canadian / HK Tax Question

    I am a Canadian resident unable to declare non-residency in Canada. I am also a US citizen.

    I have HKD Income from HK company since Aug 2015 till present.

    I also have CND Income from a Canadian company deposited into a CND bank account for work done here in HK and around Asia (emails / SKYPE calls in HK for consulting, and consulting trips)

    From my limited understanding I need to declare this income both in HK and Canada.

    It seems that I would then need to pay double tax?

    Any advice and/or contact for professional advice?


  2. #2

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    Canada : since you are a resident, you must declare and pay for worldwide income.

    Hong Kong : you have not stated whether you are resident in Hong Kong or not. You can earn money in Hong Kong without being resident - if that is the case, no Hong Kong tax.

    USA : you are a citizen : you must declare and pay for worldwide income.

    How you actually offset them, I have no idea but there should be a way to do it.

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  3. #3

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    Additional information: I am a HK Permanent resident.

    Thanks...hopefully someone can weigh in on a way to offset them


  4. #4

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    Quote Originally Posted by Golden Hawk:
    Additional information: I am a HK Permanent resident.
    Thats not relevant. Are you here and earning money while you are here? That is more relevant.

    My friend, a PR, let for 2 years to live in Malaysia. He was working in KL, being paid in Hong Kong. He did not pay HKG tax.

    In any case, this is a tad bit complicated so I'll bow out and hopefully a good accountant can give better answers.
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  5. #5

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    As US citizen residing abroad your tax exemption is at over 100k, have you Skyped that in ?
    If so, tell me how you did it.

    Secondly, you are tax liable in the country that you reside in.
    Since you can not declare non residency in big Canada, I guess you are less than 180 sumting years in HK.
    Or what is the reason ?


  6. #6

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    @ HC...sorry my bad...yes I was in HK earning HKD as a HK PR.

    @Morrison: I will not need to pay US tax as I did not make over $100,000 USD. I meant that I would need to pay both CND and HK tax.


  7. #7

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    For 2015 your residency is probably Canada, check double treaty agreement with HK
    For 2016 probably HK, check treaty.


  8. #8

    US: even though you earn less than the exclusion threshold us$100k, you are still liable to report your worldwide income and claim exclusion in your 2015 US tax return.

    HK: Basically you have to determine whether you have a HK employment or foreign employment and being seconded to HK. Any income earned under HK employment is fully taxable in HK unless you stayed < 60 days in HK in a HK tax year.

    For the foreign employment, your income is subject to HK tax on an apportionment basis based on number of days you stayed in HK. However, your may be able to claim double tax relief on this part for the 1st year (less than 180 days in HK and report all in Canada). Go and check DTA.

    CA: if you cannot declare non-residency due to number of days in CA > 180 days, you need to report worldwide income and pay tax on the worldwide income. I think you can claim foreign tax credit for the HK tax you paid. Check with your tax accountant.

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  9. #9

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    Wow...impressive first post. Thanks for the helpful information!

    I read somewhere that with the tax treaty I should not have double taxation. My situation is somewhat similar to:

    " https://geoexpat.com/forum/175/thread262394.html "

    For CDA: I will include both my income from the Canadian company and my income from my HK company and pay tax on it. Then for HK I will need to include income from both as well. It seems like double taxation?


  10. #10

    The answer to double-tax. Yes, you are double tax in the first year when you move out from your home country because Canada use a calendar year and HK use a fiscal tax year (Apr to Mar). Foreign tax credit goes to the next year filing (2016).

    Im not specialized in Canadian tax so you shall check with your Canada tax accountant for in depth tax implication which I may not be aware of.

    Golden Hawk likes this.

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