Brian Kearl, Carl Deeprose, "Leaving Canada's New High Tax Rate Regime: Considerations, Tips and Traps", 2016 Conference Report (Canadian Tax Foundation),32:1-24  

Meaning of “sojourn” (pp. 32:5)

In Thomson, the Supreme Court of Canada touched on the meaning of the word "sojourn" in obiter dictum, stating...

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Words and Phrases
sojourn

Significance of residential ties (p. 32:7)

[E]migrating Canadians should not leave an available residence behind, and should emigrate with their...

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Test of a permanent home available (p. 32:9)

In Salt, … [t]he appellant successfully argued that the tie-breaker rules deemed him to be resident...

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General effect of the s. 128.1(1)(d)(iii) limitation (p. 32:13)

[T]he emigrating individual may elect to expand the application of the deemed...

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Scope of withholding exemption/reduced withholding for period pension payments (p. 32:15)

The Canada-UK treaty…eliminates withholding for...

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Conversion of trusts deemed disposition income into “designated income” for purposes of Part XII.2 (pp. 32:16-17)

If an emigrating...

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