A taxpayer who relocated from Canada to another treaty country continued filing Canadian resident returns for years. After reconstructing the full residency history, Lepore & Company concluded there was a strong basis for treating the taxpayer as a non-resident for the relevant prior years, prepared amended filings and a detailed technical submission, and — after CRA requested and received further information — had its residency and treaty position accepted. CRA reassessed the relevant years, refunding the client more than $100,000 of Canadian income tax. The outcome was specific to this taxpayer’s facts and is not a precedent.
Category: Non-Resident Tax
Selling Shares of a Canadian Real Estate Company: The Treaty Risk for Non-Residents
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