Mr$.$ Valmont would be considered a part year resident and would only be assessed for Canadian income tax on worldwide income during the portion of the year prior to his ceasing to be a resident of Canada.

Folio S$5-$F$1-$C$1$ indicates that, in general, the CRA will view an individual as becoming a non$-$resident on the latest of three dates:

The date the individual leaves Canada.

The date the individual$$s spouse or common$-$law partner and dependants leave Canada.

The date the individual becomes a resident of another country.

While Mr$.$ Valmont departed Canada in May of $2022,$ he will be considered a Canadian resident until his family$$s departure on June $30,2022,$ as a result of the CRA concession on residency. The fact that his family remained in Canada would support this conclusion, although since he had already established the requisite intention and taken active steps consistent with that intention, the earlier date would represent a true indication of when he severed residency. The fact that he did not sell his Canadian residence would not change the result, particularly where market forces beyond his control were the cause of the delayed sale.

His Canadian salary from January $1,2022,$ to May $27,2022,$ would be subject to Canadian income tax. In addition, his U$.$S$.$ salary for the period May $28,2022,$ through June $30,2022,$ would be subject, first to U$.$S$.$ income tax, and then subsequently to Canadian income tax. In calculating his Canadian income tax, he will be entitled to a foreign tax credit for the U$.$S$.$ income tax that he has