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Compliance Checklist for Non-Residents and Deemed Residents in Canada: What’s New in 2025

Recent changes affect non-residents and deemed residents: the elimination of the Underused Housing Tax, revised rates & residency tests, and new reporting rules in CRA’s 2025 guides.

By NomadicTax Research Team · 5-8 min read

Who This Applies To

  • Non-residents: individuals who don’t reside in Canada and don’t maintain significant residential ties.
  • Deemed residents: those with certain obligated ties (government employment abroad, military, etc.) or personal circumstances triggering residency status under tax treaties. (canada.ca)

Major Changes for 2025–-2026

  • Lowest income tax rate lowered: From 15% to 14%, effective July 1, 2025, proration resulting in 14.5% for full-year 2025. (canada.ca)

  • Underused Housing Tax (UHT) eliminated: No UHT payable or returns required for 2025 or later years. Penalties/interest still apply for 2022-2024 obligations. (canada.ca)

  • Residency and Deemed Residency Rules: Updated definitions and tests clarified in the 2025 CRA guide for Non-Residents and Deemed Residents. E.g., those overseas with government credentials, or in the 19th month, certain ties, etc. (canada.ca)

Obligations You Shouldn’t Miss

  • File tax returns if required, even if your world income is mostly foreign; Canadian source income or benefits/credits may be at stake.
  • Reconcile withholding: Non-Residents may see 15% withholding on Canadian source; deemed residents may need to report global income.
  • Update CRA when your permit/immigration status changes, as eligibility for benefits/credits often depends on status.
  • Claiming credits: make sure you correctly classify expenses and claims under the new lowest rate rules.

Practical Example

Sara lives abroad, is a deemed resident because she’s a government employee posted overseas with a permit. Her world income is reported to Canada. In 2025:

  • Adjust her withholding or instalments anticipating the lowest 14.5% bracket until July 1, then 14%.
  • If she owned housing in Canada previously subject to UHT, she no longer owes UHT for 2025 or later.
  • Use the CRA’s forms for non-residents / deemed residents, especially for benefits/credits.

Tips for Smooth Compliance

  • Track your presence and ties: days in Canada, property, bank accounts—to assess your residency.
  • Maintain immigration documentation, valid permits, employer letters, etc.—crucial for deemed residency status.
  • Stay on top of CRA publications, like updated guides/forms for Non-Residents and Residency Status.
  • Retain records for foreign income even when taxed abroad, and access treaty credits if applicable.

Bottom line: For non-residents and those in borderline status, recent and proposed changes (UHT elimination, rate changes, redefined residency tests) are significant. Being fully informed now avoids lost refunds, unexpected taxes, or penalties.

Sources

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