 | Residency issues. In many cases, individuals assume they can
leave Canada and stop paying Canadian taxes, however, the Canada Customs and
Revenue Agency may see things differently. |
 | Canada's deemed disposition on departure rules. An individual must
report on his/her final Canadian tax return a disposition at fair market
value of all of his/her assets. Exceptions to this general rule
include such assets as RRSP's and real estate located in
Canada. |
 | Whether or not the individual will be required to provide security in lieu
of paying the tax resulting from the deemed disposition rules discussed
above? |
 | Whether Canadian taxes will be applied on stock options granted while a resident of
Canada? |
 | Shareholdings in private Canadian corporations must be reviewed prior to
departure. |
 | Canadian rental properties require elections be made and forms filed to
ensure that CCRA does not charge the owner 25% of the gross rents while a
Canadian non resident. |
 | Whether or not Registered Retirement Savings Plan contributions should be
maximized in the year of departure? |
 | The timing of the move must be considered. |
 | Should an election be made to file a joint return with a spouse in the
year of immigration? |
 | What is the overall tax impact of Canada's deemed disposition rules and
can this tax impact be minimized on the U.S. side? |
 | The U.S. tax ramifications of the Canada-U.S. Tax Convention of 1980. |
 | U.S. compliance costs of owning Canadian trusts and corporations. |
 | The U.S. estate and gift tax regime. |
 | Should the income earned in an RRSP be deferred or reported currently on
the U.S. income tax return. |
 | State tax considerations. |