Question
a) Wayne Greatsky is a star outfielder with the Toronto Blue Jays. In addition to his $500,000 annual baseball salary, Wayne, who lives in California,
a) Wayne Greatsky is a star outfielder with the Toronto Blue Jays. In addition to his $500,000 annual baseball salary, Wayne, who lives in California, USA, is a partner in an unincorporated sporting goods store, which is run by his brother. In the current year, Wayne's share of the profit was $75,000. Although Wayne hates cold weather, the circumstances were such that he spent a fair amount of time in Canada. Specifically, his contract came up for renewal and he spent 5 days in the last part of March and early April (before the season started) in Ontario. Next came the season - 80 home games plus the odd exhibition game which required Wayne to spend a further 118 days in Canada. Once the Blue Jays were eliminated from pennant competition, Wayne felt that he would be free to accept a very lucrative offer from Dalhousie University (in Nova Scotia) to conduct a batting clinic during the month of October, for the University's girl's softball team. Wayne accepted this contract which ran from October 1st to October 31st. Unfortunately, on the last day of the clinic, Wayne tripped over a misplaced baseball bat and broke his leg. He spent the following 28 days in a hospital in Halifax and was finally able to go home at the end of November. On December 1st, Wayne received a phone call from the Tiny Tim Fund asking him to be a guest speaker in Toronto during the weekend of December 18-19, at a fund-raising dinner. The chairman of the event informed Wayne that his airfare would be paid for out of the proceeds of the dinner, but the engagement would not include any fee. Required: Advise Wayne if he should choose to accept this speaking engagement or send a generous donation instead. Give reasons to support your answer and describe the relevant income tax implications.
b) Mrs. X, a Canadian citizen, left Canada in 2004 to settle in a country with which Canada has no tax treaty. In 2015, her daughter came to Canada to attend university. After completing her studies, the daughter decided to remain in Canada on a permanent basis. In January 2020, Mrs. X acquired a house in Canada, in which she stays when she comes to visit her daughter. She also opened a bank account in Canada, with deposits sufficient to meet her needs when she visits her daughter. Interest is paid periodically on these amounts. She has no other income from Canada. During 2020, she visited her daughter from June 1st to August 15th and from November 3rd to December 28th.
Required: Determine Mrs. X's residency status for tax purposes for 2020. Give reasons to support your answer.
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