Question
Fo r each o f the following ind ivid uals, d etermine their r esid ency status for the year end ing December 31, 2019.
Fo r each o f the following ind ivid uals, d etermine their r esid ency status for the year end ing December 31, 2019. In addition, indicate what components of their income would be subjecttoPartItaxationinCanada,eitherasaresident or a non-resident. Provide the basis f or your conclusions. Yo ur answer should not take into consideration the influence of Interna-tional Tax Treaties. Case A Gary Short is a Canadian citizen who has l ived and worked in C algary, Alberta all of his l ife. In January, 2019, he is offered a significant promotion if he will accept a position in Australia. O n accepting t his position, he establishes r esid ency in that country o n February 1 . H owever, b ecause his children wish to f inish the school year in Canada, his children and his wife d o not join him u ntil June 30, 2019. Because of the poor real estate market in his C algary neighbourhood, h is former residence is rented out u nd er a l ong term r esid ential lease b eginning July 1. Case B Sarah S loan is a U.S. citizen who l ives in Detroit, Michigan. D uring 2019 she is employed f ive d ays p er week in Wind sor, Ontario. She commutes to Wind o r o n a d aily basis. Her 2019 salary is $86,000 (Canadian). I n addition, she has $900 (C anad ian) of interest on a savings account with a Detroit b ank. Case C Byron L ong is a citizen o f France. However, having established l anded immigrant status in C anada, he has worked in this country for over 1 5 y ears. O n the unex pected d eath o f h is spouse, h e r eceives an insurance payment o f $ 2 m illion. H e decides to u se a l arge part of this payment f or an extensive r ound-the -world cruise. He arranges a two year leave of absence from his job and sails from Canada on July 1, 2019. He sells the f amily r esidence, but retains all of his C anadian b anking and brokerage accounts. Case D Hilda S tein is married to a m ember o f the Canadian armed f orces who is stationed in G ermany during the y ear 2019. She is a German citizen and has never visited C anada. During 2019, because her husband is a member of the C anadian armed f orces, she is not subject to taxation in G ermany. Case E Jessica Segal h as always lived in C anada. She h as been asked b y h er Cana-dian employer to spend part of 2019 starting on August 1 and all of 2020 and 2021, working in the company's Frankfurt office. H er employment contract requires her to return to Canada on January 5 , 2022. Jessicasells her condo and furniture and r eluc-tantly gives her beloved d og to her b rother. S he moves to Frankfurt in July, 2019.
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