. For each of the following individuals, determine their residency status for the year ending December 31,...
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For each of the following individuals, determine their residency status for the year ending December 31, 2019. In addition, indicate what ocomponents of their income would be subject to Part I taxation in Canada, either as a resident or a non-resident. Provide the basis for your conclusions. Your answer should not take into consideration the influence of Interna- tional Tax Treaties. Case A Gary Short is a Canadian citizen who has lived and worked in Calgary, Alberta all of his life. In January, 2019, he is offered a significant promotion if he will accept a position in Australia. On accepting this position, he establishes residency in that country on February 1. However, because his children wish to finish the school year in Canada, his children and his wife do not join him until june 30, 2019. Because of the poor real estate market in his Calgary neighbourhood, his former residence is rented out under a long term residential lease beginning July 1. Case B Sarah Sloan is a US. citizen who lives in Detroit, Michigan. During 2019 she is employed five days per week in Windsor, Ontario. She commutes to Windor on a daily basis. Her 2019 salary is $86,000 (Canadian). in addition, she has $900 (Canadian) of interest on a savings account with a Detroit bank. Case C Byron Long is a citizen of France. However, having established landed immigrant status in Canada, he has worked in this country for over 15 years. On the unexpected death of his spouse, he receives an insurance payment of $2 million. He decides to use a large part of this payment for an extensive round-thevworld cruise. He arranges a two year leave of absence from his job and sails from Canada on July 1, 2019. He sells the family residence, but retains all of his Canadian banking and brokerage accounts. Case D Hilda Stein is married to a member of the Canadian armed forces who is stationed in Germany during the year 2019. She is a German citizen and has never visited Canada. During 2019, because her husband is a member of the Canadian armed forces, she is not subject to taxation in Germany. Case E Jessica Segal has always lived in Canada. She has been asked by her Cana- dian employer to spend part of 2019 starting on August 1 and all of 2020 and 2021, working in the company's Frankfurt office. Her employment contract requires her to return to Canada on January 5, 2022. Jessica sells her condo and furniture and reluc- tantly gives her beloved dog to her brother. She moves to Frankfurt in July, 2019. For each of the following individuals, determine their residency status for the year ending December 31, 2019. In addition, indicate what ocomponents of their income would be subject to Part I taxation in Canada, either as a resident or a non-resident. Provide the basis for your conclusions. Your answer should not take into consideration the influence of Interna- tional Tax Treaties. Case A Gary Short is a Canadian citizen who has lived and worked in Calgary, Alberta all of his life. In January, 2019, he is offered a significant promotion if he will accept a position in Australia. On accepting this position, he establishes residency in that country on February 1. However, because his children wish to finish the school year in Canada, his children and his wife do not join him until june 30, 2019. Because of the poor real estate market in his Calgary neighbourhood, his former residence is rented out under a long term residential lease beginning July 1. Case B Sarah Sloan is a US. citizen who lives in Detroit, Michigan. During 2019 she is employed five days per week in Windsor, Ontario. She commutes to Windor on a daily basis. Her 2019 salary is $86,000 (Canadian). in addition, she has $900 (Canadian) of interest on a savings account with a Detroit bank. Case C Byron Long is a citizen of France. However, having established landed immigrant status in Canada, he has worked in this country for over 15 years. On the unexpected death of his spouse, he receives an insurance payment of $2 million. He decides to use a large part of this payment for an extensive round-thevworld cruise. He arranges a two year leave of absence from his job and sails from Canada on July 1, 2019. He sells the family residence, but retains all of his Canadian banking and brokerage accounts. Case D Hilda Stein is married to a member of the Canadian armed forces who is stationed in Germany during the year 2019. She is a German citizen and has never visited Canada. During 2019, because her husband is a member of the Canadian armed forces, she is not subject to taxation in Germany. Case E Jessica Segal has always lived in Canada. She has been asked by her Cana- dian employer to spend part of 2019 starting on August 1 and all of 2020 and 2021, working in the company's Frankfurt office. Her employment contract requires her to return to Canada on January 5, 2022. Jessica sells her condo and furniture and reluc- tantly gives her beloved dog to her brother. She moves to Frankfurt in July, 2019.
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Determination of Residential Status of following persons CASE A This is a case of Factual Residence ie leaving Canada In case of factual residence the ... View the full answer
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