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Revenue Ruling

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 Rev. Rul. 69-46

1969-1 C.B. 365

IRS Headnote

Canadian residents are exempt from tax on remuneration received for teaching in the United States under article VIIIA of the United States-Canada Tax Convention even though they have not taught in Canada prior to that time.

Full Text

Rev. Rul. 69-46

A Canadian resident, who qualified as a teacher, visited the United States for the purpose of serving as a teacher in a school in the United States during the academic year ended June 30, 1968. Prior to that time he had not served as a teacher in Canada. Held, under Article VIIIA of the Income Tax Convention between the United States and Canada, the Canadian resident is exempt from Federal income tax of the United States on the remuneration he received for teaching in the United States during the academic year ended June 30, 1968, since there is no requirement in the convention, as a prerequisite for exemption under Article VIIIA, that the taxpayer must have taught in Canada prior to teaching in the United States.