4561 Lecture 10 Overheads for Posting July 19 10

4561 Lecture 10 Overheads for Posting July 19 10 - updated...

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updated July 18/10 B. Emigration Case - Mr. Black Residency Status Consider whether Brad will still be resident based on residential ties - family (wife staying in Canada for non-winter months) - dwellings (left in Canada) - other personal property ties (investments) - social ties (no info) - permission for indefinite stay - few ties in Caymans (renting apt) Consider ways to cut residential ties - rent or sell house - change address, etc - minimize visits to Canada - wife spends entire year in Caymans - establish ties in Caymans (give e.g. – join club, purchase home, etc.) Conclude on residency status If non-resident when leave - deemed disposition at FMV - exception for Can RE - i.e., house, cottage - exception for RRSP - post security to defer tax to actual disposition - Part XIII w/h tax on dividends, interest, rental, RRSP withdrawals, etc. - Part I tax on employment income (e.g. stock option benefits when realized), business income/loss (i.e. restaurant mall business earned through a partnership), TCG on TCP (future sales of house, vacant land, CCPC) - Public company shares not TCP - can unwind if return in 5 years or less - must report assets > $25K - (note that s. 216 return for rental income is not discussed as it is not in the course syllabus) $40,000 Moving allowance - taxable in Canada - no deduction for moving expenses when you move offshore - tax planning: ask for $40,000 reimbursement, receive reimbursement from Cayman Islands
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Stock options (granted to buy 1,000 shares in 2001, exercise price $20, stock trading at $10 at grant date and currently at $25) - discussion of tax treatment - no deemed disposition on departure from Canada - taxable in Canada later: when exercised under Part I by non-resident
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This note was uploaded on 08/10/2010 for the course LAPS 4561 taught by Professor Frankovic during the Summer '10 term at York University.

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4561 Lecture 10 Overheads for Posting July 19 10 - updated...

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