Cases
The Queen v. Taylor, 91 DTC 5131 (FCA)
In 1983 a resident of California paid $325,226 in foreign non-business income taxes, became a resident of Canada on November 1, 1983, and earned...
The Queen v. Bergelt, 86 DTC 6063, [1986] 1 CTC 212 (FCTD)
The taxpayer ceased to be a resident of Canada in September 1980 when he moved to California to work as a senior controller with a U.S. company...
Griffiths v. The Queen, 78 DTC 6286, [1978] CTC 372 (FCTD)
A retired Canadian executive who amicably separated from his wife and moved to a Carribean island in order to live in, and sail, his yacht,...
Beament v. Minister of National Revenue, 52 DTC 1183, [1952] CTC 327, [1952] 2 S.C.R. 486
On the outbreak of the Second World War, the taxpayer, before going for service overseas, ceased renting a room in his parents' house, and stored...
See Also
Grant v. The Queen, 2006 DTC 3071, 2006 TCC 373, aff'd 2007 DTC 5351, 2007 FCA 174
On December 24, 1998, the taxpayers borrowed an aggregate of approximately U.S.$1 billion from the CIBC, and lent the same sum to a U.S....
Administrative Policy
6 May 2009 External T.I. 2009-0311951E5 F - Résidence au Canada pour fins fiscales
An individual, who became a resident of Bermuda in September 2007 in order to take up employment there, returned to Canada in June 2009. How will...
17 January 2017 Internal T.I. 2016-0647161I7 - Capital gains of a partnership
Is an individual taxpayer who is a member of a U.S. partnership (“Partnership”) and who immigrated to Canada during a taxation year, thereby...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 96 - Subsection 96(8) - Paragraph 96(8)(c) | no reciprocal application to pre-immigration capital gains | 83 |
S5-F1-C1 - Determining an Individual’s Residence Status
The date upon which a Canadian resident individual leaving Canada will become a non-resident ... will usually coincide with the latest of the...
85 C.R. - Q.20
A non-resident, who is a member of a partnership not carrying on business in Canada, will be taxed under Part I for his share of the income of the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 2 - Subsection 2(3) - Paragraph 2(3)(b) | 27 |
84 C.R. - Q.35
A non-resident who only occasionally visits Canada to perform directorship duties will not thereby be considered to be employed in Canada...
Articles
Christine Hung, "Taxation of an Immigrating Partner's Income from a Foreign Partnership in the Year of Immigration", Canadian Current Tax, Vol. 9, No. 9, June 1999 [9]
"The immigrant partner is required to include in his or her income for Canadian tax purposes only that part of the foreign partnership income...