Problem 11 The taxpayer came to Canada in 1977. He stayed in Canada until 1987. Prior...
Fantastic news! We've Found the answer you've been seeking!
Question:
Transcribed Image Text:
Problem 11 The taxpayer came to Canada in 1977. He stayed in Canada until 1987. Prior to 1987 the taxpayer studied engineering and obtained an engineering degree. He also married. In 1987 the taxpayer went to England for post-graduate studies; he returned to Canada with his wife and two children in 1989. For three years he worked as an engineer in Canada. In 1992 he moved to the United States with his family. He remained there continuously until 2012 when he became a naturalized U.S. citizen. Also in 2012, following the loss of his job in the United States, he returned to Canada to take a new job. The new job lasted for two years. During 2013 and 2014 the taxpayer remained in Canada, working as a self- employed consultant. In 2015 he moved back to the United States. There he worked as an employee for six months. Thereafter, he practiced his profession on a self-employed basis working for various companies in the United States which required his services. He practiced his profession from an office in his home. An apartment was occupied by the taxpayer under a lease entered into in 2013 and renewed yearly thereafter. When the taxpayer returned to Canada in 2012 he bought a house in Mount Albert, Ontario. A few months later, after the necessary domestic arrangements had been made, the taxpayer's wife and children joined him, and the family lived in the house at Mount Albert. Marital difficulties arose. The taxpayer's wife and children remained behind in Mount Albert when the taxpayer returned to the United States in 2015. The taxpayer visited Canada rather infrequently after 2015. With two exceptions, his post-2015 visits to this country were for the purpose of seeing his children, and were made three or four times a year. Although during those visits he stayed in the Mount Albert home, he appears to have stayed as a visitor only and not a person whose home it was. During the post-2015 period, the taxpayer made monthly payments to his wife for her support and that of the children. The two exceptional post-2015 visits were made in order to fulfill a contract made by the taxpayer with a company that needed the services of an engineer who had expertise in U.S. military specifica- tions. The first such visit, in June and July 2018, lasted for thirty-two days. The second, in August of that year, lasted for sixteen days. In 2018, the taxpayer held what he said was non-resident membership in the Ontario Association of Professional Engineers. He also held membership in the Engineering Institute of Canada and the Canadian Society of Mechanical Engineers. The taxpayer maintained a bank account in Newmarket, Ontario. He mistakenly filed a 2018 tax return with the Canada Revenue Agency, indicating that he resided in Mount Albert. Evaluate, in detail, the alternatives to the residence issue for the taxpayer in 2018. Provide support for your conclusions. Problem 11 The taxpayer came to Canada in 1977. He stayed in Canada until 1987. Prior to 1987 the taxpayer studied engineering and obtained an engineering degree. He also married. In 1987 the taxpayer went to England for post-graduate studies; he returned to Canada with his wife and two children in 1989. For three years he worked as an engineer in Canada. In 1992 he moved to the United States with his family. He remained there continuously until 2012 when he became a naturalized U.S. citizen. Also in 2012, following the loss of his job in the United States, he returned to Canada to take a new job. The new job lasted for two years. During 2013 and 2014 the taxpayer remained in Canada, working as a self- employed consultant. In 2015 he moved back to the United States. There he worked as an employee for six months. Thereafter, he practiced his profession on a self-employed basis working for various companies in the United States which required his services. He practiced his profession from an office in his home. An apartment was occupied by the taxpayer under a lease entered into in 2013 and renewed yearly thereafter. When the taxpayer returned to Canada in 2012 he bought a house in Mount Albert, Ontario. A few months later, after the necessary domestic arrangements had been made, the taxpayer's wife and children joined him, and the family lived in the house at Mount Albert. Marital difficulties arose. The taxpayer's wife and children remained behind in Mount Albert when the taxpayer returned to the United States in 2015. The taxpayer visited Canada rather infrequently after 2015. With two exceptions, his post-2015 visits to this country were for the purpose of seeing his children, and were made three or four times a year. Although during those visits he stayed in the Mount Albert home, he appears to have stayed as a visitor only and not a person whose home it was. During the post-2015 period, the taxpayer made monthly payments to his wife for her support and that of the children. The two exceptional post-2015 visits were made in order to fulfill a contract made by the taxpayer with a company that needed the services of an engineer who had expertise in U.S. military specifica- tions. The first such visit, in June and July 2018, lasted for thirty-two days. The second, in August of that year, lasted for sixteen days. In 2018, the taxpayer held what he said was non-resident membership in the Ontario Association of Professional Engineers. He also held membership in the Engineering Institute of Canada and the Canadian Society of Mechanical Engineers. The taxpayer maintained a bank account in Newmarket, Ontario. He mistakenly filed a 2018 tax return with the Canada Revenue Agency, indicating that he resided in Mount Albert. Evaluate, in detail, the alternatives to the residence issue for the taxpayer in 2018. Provide support for your conclusions.
Expert Answer:
Answer rating: 100% (QA)
The taxpayers residency status for 2018 is unclear There are a number of factors that could be used ... View the full answer
Related Book For
Federal Taxation 2016 Comprehensive
ISBN: 9780134104379
29th edition
Authors: Thomas R. Pope, Timothy J. Rupert, Kenneth E. Anderson
Posted Date:
Students also viewed these accounting questions
-
In 2019, Mike Taxpayer deducted losses he incurred from an Internet retail business operated by Mike and his sister. Following a recent audit, the Internal Revenue Service determined that Mikes...
-
Prior to the Taxpayer Relief Act of 1997, taxpayers could defer a gain on the sale of a principal residence sold before May 7, 1997, if they purchased and occupied a new principal residence within...
-
In March 1977 (during an "energy crisis",) the U.S. Federal Energy Administration (FEA) conducted a personal interview survey of a sample of homes where there was a heating load (that is, the outside...
-
how good are your with western civilization history?? choose one of the following topics topic 1: based on the texts by kafka and eliot, (writing on one or the other or both), discuss how the writers...
-
What are the uses of performance appraisal?
-
Laplaces equation in polar coordinates, Eq. (8.11), is complicated by the variable radius r. Consider the finite difference mesh in Fig. P8.106, with nodes (i, j) at equally spaced Δθ and...
-
Distinguish different types of religious practitioners.
-
Weller Industries is a decentralized organization with six divisions. The companys Electrical Division produces a variety of electrical items, including an X52 electrical fitting. The Electrical...
-
Eleven years ago, Park Ltd. acquired 40% of the common shares of Sabala Ltd. for $3million.ThisgaveParkasignificantinfluenceoverSabala.Atthatdate, Sabala had $3.5 million of retained earnings and...
-
Suppose that the two-dimensional vectors (X1, Y1), (X2, Y2), . . . , (Xn, Yn) form a random sample from a bivariate normal distribution for which the means of X and Y, the variances of X and Y , and...
-
3. Dial Soap Company developed a new soap for men and test marketed the product in two cities. The nample information is reported below. At the 0.05 significance level, can we conclude there is a...
-
A principal whose existence and identity are not known to third parties. a. agent b. agency by necessity c. agency by ratifi cation d. apparent a uthority e. attorney in fact f. express a uthority g....
-
The agency that results when a person fails to support his or her spouse or minor children. a. agent b. agency by necessity c. agency by ratifi cation d. apparent a uthority e. attorney in fact f....
-
A party to a contract who transfers his or her rights to a third party. a. assignee b. assignment c. assignor d. bankrupt e. delegation f. guarantor g. incidental benefi ciary h. novation i....
-
Indicate whether each of the following statements is true or false by writing T or F in t he a nswer c olumn. The Statute of Frauds specifi es that certain kinds of contracts must be in w riting.
-
Indicate whether each of the following statements is true or false by writing T or F in t he a nswer c olumn. The requirement of writing does not apply in auction sales.
-
Compose the operational guidelines for the given Entity-Relationship Diagram. Exclude attribute descriptions and focus on specifying all cardinalities, participation constraints, and identifying...
-
(a) What is the focal length of a magnifying glass that gives an angular magnification of 8.0 when the image is at infinity? (b) How far must the object be from the lens?
-
Explain the relationship between dividends and earnings and profits.
-
Sometimes taxpayers may not be able to file their tax returns by the normal due date. Are extensions available? How long are the extensions? How long are the extensions? Do extensions enable...
-
King Corporation is a profitable manufacturing concern with $800,000 of E&P. It is owned in equal shares by Harry and Wilma, husband and wife. Both individuals are actively involved in the business....
-
What are the main characteristics of the various systems of social differentiation within egalitarian and rank societies?
-
The United States and Canada are two of only 33 countries that have jus soli, the right to citizenship of any individual born on their soil. Why do you think this right is so limited, and do you...
-
What are the responsibilities of the governments toward the stateless? Do the United States and other powerful nations have responsibilities toward groups such as the Rohingya? Following the...
Study smarter with the SolutionInn App