Question
(Residency A fter D eparture From Canada) Mr. Valone is a U. S. citizen. However, since o btaining permanent r esidence status in 2005, he
(Residency A fter D eparture From Canada) Mr. Valone is a U. S. citizen. However, since o btaining permanent r esidence status in 2005, he has b een employed on a f ull time b asis in London, O ntario. H is employer is a C anad ian subsidiary of a m ulti-national corporation that operates in a number of different countries. The h ead o ffice of the company is in the U nited S tates. Mr. Valone h as been very successful in his position with the C anad ian subsid iary. B ased on this, h e h as been offered a promotion which involves a significant increase in salary. However, this promotion is conditional on his m oving to the company's h ead o ffice in Philadelphia no later than March 1, 2019. Given the sizable increase in r emuneration, Mr. Valone f inds this offer too good to pass up. As he is a U.S. citizen, h e h as no d ifficulty getting the appropriate d o cumentation to establish his r esid ency in the U.S. H e r elinquishes h is C anad ian d r iver's licence, as well as his p rovincial health care card . As r equired b y h is employer, h e is at h is d esk in the new work location in the U. S . o n M a r c h 1 . Mr. Valone and his spouse have two children who are attending a private school in London. The current semester at this school lasts u ntil June 15, 2019. In order to provide continuity in their ed u cation, Mrs. Valone d ecid es that she and child r en will r emain in C anad a u ntil the current semester is finished. T hey d epart on J une 20, 2019. The r eal estate m arket in L ond o n h as been somewhat slow of late. As a consequence, the Valone's house is not sold u ntil October 5 , 2019. Required: Fo r p urposes of assessing C anad ian income tax es, d etermine when Mr. Valone ceased to be a C anadian r esident and the portion of his annual income which would be assessed f or C anad ian tax es. Ex plain y our conclusions.
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