Income earned in NJ for an expat/NJ sourced income for nonresident - TAX ADVICE NEEDED

[jerseymd2010]

Hi All,

Looking to relocate north of the border to Toronto, Ontario. I am a physician. US Citizen/Canadian PR. Looking for some advice on what would be considered 'NJ sourced income.' As a nonresident of NJ, you have to report income from all sources (both inside and outside NJ) as well as income only from New Jersey sources. As a nonresident, your income tax is prorated and you have to pay on sources of income from NJ. Wondering what would be considered NJ sourced if I am working remotely from Toronto.

Assuming that I have a permanent home in Toronto and am working 100% remotely thru telemedicine from my US based income, what would be considered NJ sourced from the following:

1. Rental property in NJ - earning about 10-15k annually
2. Collaborating physician- collaborating with NJ based nurse practitioners - ~$30k annually - 1099-misc given, address on record is NJ
3. Telemedicine - ~$100k income - working for companies based in Silicon Valley, Texas - however I get my paychecks deposited into bank accounts/addresses on file in NJ. Although I hold licenses to practice medicine in NJ, FL, TX and other states, all of the income is lumped together and received as a 1099-misc at the end of the year. My 'address on record' is my NJ address for these companies.
4. Working in person in Toronto, ON - earning about 200k CDN

Out of the 4 streams of income above, what would be considered NJ sourced? Would it be just the rental property? Is there a way to avoid double taxation? Thank you all in advance; please ask questions if anything is not clear.

[pk]

@jerseymd2010 , generally speaking, income is sourced to where the work is performed.  Thus is you are  a resident of Canada, the remote earnings  would be sourced and taxed in Canada.   Because you are citizen of USA, you would also  be taxed by USA on your world income  and given credit for taxes paid to Canada--- suggest you  consult a tax professional ( given the size of the income you are talking about).  You would generally be non-resident in NJ and generally will not have a NJ  sourced income.  A lot of this depends on how you are  earning in the USA --as a self-employed, or through an entity that you own or  direct contract with a doctor's office or what. Therefore I again suggest a tax professional help.  It would be mistake to do self-help unless you are  very familiar with US tax laws, NJ tax laws, Canadian Tax laws and the US-Canada tax treaty.  There  will always be the question of closer connection .

I can only help , if you really insist in doing it by yourself and with details of your  arrangement for  earnings streams, how long you plan to stay in Canada etc.

[pk]

@jerseymd2010 , generally speaking, income is sourced to where the work is performed.  Thus is you are  a resident of Canada, the remote earnings  would be sourced and taxed in Canada.   Because you are citizen of USA, you would also  be taxed by USA on your world income  and given credit for taxes paid to Canada--- suggest you  consult a tax professional ( given the size of the income you are talking about).  You would generally be non-resident in NJ and generally will not have a NJ  sourced income.  A lot of this depends on how you are  earning in the USA --as a self-employed, or through an entity that you own or  direct contract with a doctor's office or what. Therefore I again suggest a tax professional help.  It would be mistake to do self-help unless you are  very familiar with US tax laws, NJ tax laws, Canadian Tax laws and the US-Canada tax treaty.  There  will always be the question of closer connection .

your rental income would definitely be sourced to NJ and so you have to file a Non-Resident NJ return to cover that

I can only help , if you really insist in doing it by yourself and with details of your  arrangement for  earnings streams, how long you plan to stay in Canada etc.