Tax Residency and International Implications

Canadian Tax Essentials: Personal & Corporate · 4:48

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Lyrics

[Verse 1]
Sarah moved from Toronto down to Dallas last July
Kept her cottage and her RRSP, now she's wondering why
Tax letters keep arriving at her Canadian door
CRA says residential ties matter more than before
One-eighty-three days is the magic number line
But ties that bind can make you Canadian by design

[Chorus]
Residential ties, where do you belong
Primary ties are strong, secondary play along
Spouse and home and kids, that's the primary three
Secondary ties like banks and cards, they add complexity
One-eight-three days or ties that bind
Tax residency's defined, keep the rules in mind

[Verse 2]
Mike's corporation started here but moved to Bermuda's shore
Board meetings held remotely, but where's the central core
Mind and management location, that's the corporate test
Place of incorporation matters, but control's the real quest
Canadian source income follows you around the world
Even when your residency flag has been unfurled

[Chorus]
Residential ties, where do you belong
Primary ties are strong, secondary play along
Spouse and home and kids, that's the primary three
Secondary ties like banks and cards, they add complexity
One-eight-three days or ties that bind
Tax residency's defined, keep the rules in mind

[Bridge]
Deemed resident rules can catch you by surprise
Sojourning more than half the year, despite your foreign ties
Non-resident withholding tax on Canadian source pay
Treaty shopping won't protect you if the substance doesn't stay
Part-year residents must split their income streams
Nothing's ever simple in these international schemes

[Verse 3]
Lisa works for Global Corp, they sent her overseas
Three year posting to Hong Kong, but kept her health plan fees
Primary ties are severed, secondary ties reduced
Tax treaty says she's foreign now, from Canadian tax excused
But rental income from her condo still gets taxed at source
Twenty-five percent withholding follows its prescribed course

[Final Chorus]
Residential ties, where do you belong
Primary ties are strong, secondary play along
Spouse and home and kids, that's the primary three
Secondary ties like banks and cards, they add complexity
One-eight-three days or ties that bind
Tax residency's defined, keep the rules in mind

[Outro]
When borders blur and money flows
Tax residency rules expose
Where you live and where you pay
CRA will have their say

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