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The Wrapbook Team consists of individuals who are thrilled about building modern software tools for creators. We’re a team of compassionate and curious people dedicated to solving complex problems with sophisticated solutions. You can find us across the U.S. and Canada.
At Wrapbook, we pride ourselves on providing outstanding free resources to producers and their crews, but this post is for informational purposes only as of the date above. The content on our website is not intended to provide and should not be relied on for legal, accounting, or tax advice. You should consult with your own legal, accounting, or tax advisors to determine how this general information may apply to your specific circumstances.
Do you have US residents or loan-outs working as employees in a Canadian province?
Companies employing both union and non-union US resident workers working in a Canadian province—except Quebec—can run payroll for those employees through Wrapbook.
The following will break down how you can manage your cross-border payroll needs. But first, let’s explore the many considerations production companies and studios must keep in mind when their US workers are hired onto a project filming in Canada.
Film production companies and studios with US workers employed in Canada must navigate two distinct payroll systems simultaneously. As a result, multiple compliance considerations must be kept in mind.
For one, when US workers perform services in Canada, the company typically must register with the Canada Revenue Agency (CRA) and set up a Canadian payroll account. Secondly, the production company must withhold Canadian federal and provincial income taxes as well as contributions for the Canada Pension Plan (CPP) and Employment Insurance (EI), even if the workers are US citizens.
The Canada–US Tax Treaty prevents double taxation. Although Canadian taxes may be withheld, US workers can often claim foreign tax credits on their US returns. Therefore, the production company’s payroll system must be able to calculate and coordinate both US and Canadian tax withholdings to reflect these treaty benefits.
When a production company has US workers in Canada, it’s imperative that they are correctly classified as employees or independent contractors, as Canadian employment laws—benefits, overtime, leave, etc.—may apply if they’re considered employees in Canada. Providing workers with the necessary Canadian identification, such as an Individual Tax Number or Business Number, can avoid delays and compliance issues.
With payments potentially made in Canadian dollars, your payroll system must manage currency conversion and fluctuations accurately. Ideally, a payroll platform designed for cross-border scenarios can automate calculations and reduce errors.
Maintaining detailed records and issuing the proper end-of-year tax documents, such as Canadian T4 slips alongside US W-2s, is necessary for compliance in both jurisdictions.
By addressing these areas—registration, tax treaty benefits, employee classification, system integration, and meticulous documentation—film production companies can effectively manage cross-border payroll compliance for US workers in Canada.
If a company plans to have US workers employed in Canada, it's imperative to have specialized payroll services familiar with cross-border requirements, such as reporting and benefits administration, to ensure both Canadian and US tax regulations.
Moreover, using a flexible payroll system that can adapt to the cyclical nature of the film industry where US workers will be employed in Canada on a project-by-project basis is key, as is a platform where compliance with provincial and Canadian federal labor laws is built into the system.
Combined, these features can significantly reduce payroll errors and administrative burdens.
As mentioned, Wrapbook now allows for production companies and studios to manage their cross-border payroll needs. Let’s find out how.
Wrapbook makes it a friction-free experience for both companies and their US workers when they set up a project in Canada.
During project setup, companies will see a Canada option, and their workers will add their Individual Tax Number (ITN) or Business Number (BN) during onboarding. Canadian provincial and federal income taxes will be deducted when companies run payroll, and year-end documents will be provided to workers (T4 or T4A-NR).
Companies will see a Canada option when entering a specific work location address. With the Canada option selected, the company can then enter a Canadian address. Please note: Addresses are based on Google Maps, same as the United States.
A legal addendum is set up as an attestation. When a customer adds a Canadian work location to a project for the first time, they will be required to attest. Only Company Admin roles can attest. If a company has yet to attest, non-company admin roles cannot add a Canada work location to any project.
The attestation is only required once per company; once attested, you will not be prompted again on any project and any role with access to edit project settings will be able to add a Canada work location.
With a worker invited to the project with a Canadian work location, the company will see the ITN (Individual Tax Number) or BN (Business Number) in the Worker Profile under Personal Information. If the number is missing, the interface will show the employee or loan-out is missing this information. If entered, the number will appear, full nine digits.
In case you’re not already familiar with Canadian tax forms, here’s a breakdown of the most common documents:
For US residents working in Canada with or without a waiver, employees will receive a T4 and loan outs will receive a T4A-NR.
When running payroll in Step 2 - Review Payroll, Provincial and Federal Income Tax will be shown as deductions.
As mentioned above, employees will be subject to Canadian provincial income tax and Canadian federal income tax in addition to the usual US taxes. The lowest income tax rate for each province and federally will be implemented. Loan-outs are subject to 15% income tax.
As of this writing, Canada’s federal income tax stands at 15%. The various Canadian provincial income taxes break down as follows:
When running payroll in Canada with Wrapbook, the system will calculate both US and Canadian income taxes. The US taxes are based on the worker's residence. For Canadian taxes, it will calculate Provincial Income Tax and Federal Income Tax without annualizing the payment, implementing only the lowest tax bracket in each province and at a federal level. The sum of all Canadian taxes will be subtracted from the US Federal Income Tax. If the US Federal Income Tax amount isn't enough to cover the Canadian taxes, the payroll will flag that the FIT was insufficient.
For example, let’s say a non-resident worker owes Canadian federal income tax of $193.51 CAD, which converts to $143.18 USD, and BC income tax of $65.28 CAD, which converts to $48.30 USD. The total amount owed is $191.48 USD. Let’s also say that the same worker owes US federal income tax (FIT) of $76.39 USD. Because that worker’s Canadian taxes are greater than the US FIT, they subsequently owe no US FIT.
Note: Wrapbook will capture and store the daily conversion rate according to the Bank of Canada. On banking holidays where the rate is not available, we will use the rate from one business day earlier.
To ensure workers are aware of their At year end, Wrapbook will supply digital versions of the T4 slip for employees and the T4A-NR for loan-outs.
When hired onto a project with a Canadian work location, you will be asked during onboarding for an ITN or BN.
Once selected, you will be promoted for an Individual Tax Number or Business Number. This page will include a link to ITN or BN instructions along with a warning stating if this number is not provided there will be delays in generating end-of-year documents and Canadian taxes.
Wrapbook makes it easier to do more, faster, in both the US and Canada. See how our next-gen tech platform is shaping the new possible of production payroll and accounting by taking a tour of it.
Still have questions about our cross-border payroll options? Our Help Center offers additional information on our full international payroll support, including that for US citizens working in Canada with a Canadian Tax Waiver. And for any additional issues or needs, you can always reach out to our Support Team.
