a

Marco is a self-employed super hero from San Francisco, USA who is looking for work in Brampton, ON, Canada. He visited Toronto between August 10 – 15, 2020 and signed a lease for a new apartment in downtown Toronto on the 14^th. He returned home to Chicago after his trip to Toronto and cancelled the lease on his apartment as of December 1, 2020. On December 1, 2020, he moved his belongings to Toronto and began saving people there.

Required: EXPLAIN Marco’s residency status for 2020 and 2021. At what point would he become a Canadian resident for tax purposes and why? What are the tax consequences?

b

Jude is a magazine editor for a New York magazine office. He lives in Cornwall, ON, Canada and crosses the border five days a week to perform his employment duties, and then returns home to Cornwall at night. He earned $110,000 Canadian at his editor job in 2020. In addition, he taught part-time at St. Lawrence College in Cornwall earning $22,000 in 2020, plus he earned $500 Canadian in interest from a Canadian bank in 2020.

Required: EXPLAIN Jude’s residency status for 2020. What are the tax consequences? Show specific calculations to support your answer for world wide income.

c

Arnold is married with a new born baby and lives in Winnipeg, MB, Canada. He has been accepted into medical school in Boston, USA. He moved to Boston on September 1, 2020 and started his residency in Boston the following week. His wife and baby stayed behind in Canada so the grandparents could help look after the baby. The family home in Winnipeg was sold on November 20, 2020 and his wife and child moved to Boston to be with Arnold.

Required: Explain the type of resident Arnold would be considered for Canadian tax purposes for 2020. If his residency status changed during the year, what day did it change? What period of income would be taxable in Canada during 2020?