Important Information:
The information presented is subject to change and is for educational purposes only. It should not be considered tax or legal advice. Before acting on any of the information presented in this article, it is important to seek the advice of a qualified tax and legal professional, who will be able to make recommendations tailored to your specific circumstances.
1 CRA Income Tax Folio S5-F1-C1, Determining an Individual’s Residence Status (November 26, 2015)
2 ITA 128.1(c)
3 Treaty ART. XVIII
4 Treaty ART. XVIII, ITA Paragraph 81(1)(r)
5 CRA Income Tax Folio S5-F3-C1, Taxation of a Roth IRA (February 3, 2022)
6 Treas. Reg. Sec. 301.7701-7
7 IRC Sec. 1297
8 IRS Rev. Proc. 2020-17 (March 16, 2020)
9 CRA Income Tax Folio S1-F3-C3 Principal Residence (July 25, 2019)
10 IRS Publication 523, Selling Your Home (Feb. 6, 2025)
11 IRC Secs. 957, 958; Treas. Reg. Sec. 301.7701-2(b)(8)