If an individual is employed solely outside of Canada, and is not , and has never been, a resident of Canada, no withholdings on payments are required. However, the corporation would generally be required to file a T4 in respect of the non-resident individuals total remuneration. One exception to this rule, would be where the total remuneration for the year is less than $500. This requirement to file a T4 is not conditional upon the payee being taxable in Canada.
CRA also opined that participation in meetings using the Internet or telephone from outside of Canada would not constitute performing the services in Canada.
Action Item: Ensure you are filing T4s in respect of non-resident employees providing services outside of Canada.