AFM363 Lecture Notes - Lecture 2: Section 15 Of The Canadian Charter Of Rights And Freedoms, Tax Treaty, List Of Highest-Grossing Films

• School: University of Waterloo
• Department: Accounting & Financial Management
• Course: AFM363
• Professor: Dan Rogozynski

Document Summary

Residency and tax: required to pay tax on worldwide income in country of residency. Determining residency for individuals: https://www. canada. ca/en/revenue - agency/services/tax/international -non-residents/information -been-moved/determining-your- residency-status. html. Common law test: determines residency based on primary (house and spouse) and secondary (licensing, personal property, bank accounts, etc). Deeming rule test: determines deemed residency status based on the 183-day sojourning test. Only used for non-residents or the period in the year where a taxpayer is a non -resident. Does not include commuting to or from work. Determining residency for individuals: https://www. canada. ca/en/revenue - agency/services/tax/international -non-residents/information -been-moved/determining-your- residency-status. html: gather all the facts (before, during, and after move) for common-law test, develop arguments based on facts (resident vs non -resident). For the tax year of the residency change. Should mention foreign tax treaties , ftc, and pay tax on worldwide income. Determining residency for corporations: unlike individuals, the deeming rules of incorporation after 1965 comes first. Losses on ccpc shares or loans are abil.