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

Summary Under

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Words and Phrases

Summary Under

Significance of residential ties (p. 32:7)

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

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

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...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

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

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

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

Summary Under

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

If an emigrating...

The text of this content is paywalled except for the first five days of each month. Subscribe or log in for unrestricted access.

You are here