Question: Mr. Byrde has been employed as a full-time analyst in Toronto, Ontario since 2014. He is employed by a Canadian subsidiary of a U.S. company

Mr. Byrde has been employed as a full-time analyst in Toronto, Ontario since 2014. He is employed by a Canadian subsidiary of a U.S. company that has its head office in Lake of the Ozarks, Missouri. While he has permanent resident status in Canada, he is a U.S. citizen. The U.S. parent company has offered Mr. Byrde a significant promotion that involves a large increase in salary. This promotion requires that he move to the companys head office in Missouri no later than June 1, 2022. Mr. Byrde finds this to be an offer he cannot refuse. As Mr. Byrde is a U.S. citizen, moving to the United States presents no problems for immigration however he is unsure of how much it will take to move he and his spouse have three children, all of whom are attending school in Toronto, Ontario. They would like to remain in Toronto until the end of the school year. The Byrdes will need to advice on what to do with their club memberships, bank accounts and investments. In addition, the Byrdes own their home in Toronto and they are unsure how long it might take to sell it or if it might be better to keep it as an investment property. Required: Write a short memo advising Mr. Byrde on the potential tax consequences of his move specifically on the issue of his residency status for purposes of Canadian income tax.

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