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Bert, a computer technician with ABC Ltd. in Toronto, Ontario, accepted a transfer to Los Angeles, California, and committed to stay there for at least
Bert, a computer technician with ABC Ltd. in Toronto, Ontario, accepted a transfer to Los Angeles, California, and committed to stay there for at least four years. On May 1, 2021 , he flew to Los Angeles and began work on the same day. On July 30 , 2021, Bert's common-law partner, Ernie, concluded the sale of their house, closed their joint bank accounts, shipped their personal possessions, and departed for Los Angeles. A. Which one of the following best indicates Bert's residence status for Canadian income tax purposes in respect of the 2021 taxation (calendar) year? (2014 CPAO) (2 marks) (a) a resident of Canada pursuant to the common law (b) a resident of Canada pursuant to the deeming provision (i.e., paragraph 250 (1) (a) of the ITA) (c) a part-year resident of Canada (d) a non-resident of Canada B. Which one of the following best serves as the basis to determine Bert's liability for Canadian income tax in respect of the 2021 taxation (calendar) year? (2014 CPAO) (2 marks) (a) his worldwide income for the 2021 taxation (b) his worldwide income for the 2021 taxation (calendar) year, subject to the Canada-U.S. Tax Treaty (c) his worldwide income for the period from January 1,2021, to may 1, 2021 (d) his worldwide income for the period from January 1,2021, to July 30,2021
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