# Reporting Dividends from T5 for a JWROS Account



## newfoundlander61 (Feb 6, 2011)

Received my first T5 this year due to dividends paid in Nov from RY, as the the account is joint (both our names on the top portion of T5) and both our money from house sale do I simple divide the numbers from boxes 24-26 on the T5 and enter them into each of our returns. Slip has my SSN on it but I was expecting that anyway. Thanks for any info. As this is my initial T5 reporting I want to be consistent in my tax filing going forward as the T5's increase. At some point I will sell a holding and was also wanting to know if this way of reporting the T5's can be used for any capital gains as well in the future. Wouldn't dare call CRA as I would be on hold for days this time of the year  Thanks for any help with this.

Paul


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## kcowan (Jul 1, 2010)

You tax software will ask for the split assuming you are filing jointly. I changed the split one year and had all the backup justification. CRA never asked. I think they just care that 100% gets declared.


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## newfoundlander61 (Feb 6, 2011)

We always file our own individual tax returns via TurboTax but I just complete them both as I go along entering the data.


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## stardancer (Apr 26, 2009)

This split also applies to capital gains/losses. My husband and I split all the investments this way


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## pwm (Jan 19, 2012)

It would be wonderful if one could split investment income arbitrarily from a joint account with your spouse to pay less tax, but unfortunately that is not the case. CRA's "Attribution Rule" applies, which states that the investment income is claimed by the person who earned the money which was used to buy the security that produced the investment income. If your wife did not work outside the home, then you are not allowed to split the T5. There are a few options that come to mind where one could split:

o Your wife worked and contributed 50% to buy the security. Then you could split the T5 income at 50%.
o Your wife got an inheritance or won a lottery which she used to buy the security. Then she could claim 100%
o You loaned the money to your wife at the government prescribed rate to buy the security and she paid you back the loan with interest. Then she could claim 100% of the T5 income.
o Your wife bought the security with money from her RRSP/RRIF which is considered to be her money and not yours. If she did not work, then a spousal RRSP/RRIF would work. She could claim 100% of the T5 in that case.

In summary, if the amount involved is ~$100 than you shouldn't worry. In my case however it's ~$100k so that is entirely a different matter, and I therefore pay close attention to how I handle the situation.


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## newfoundlander61 (Feb 6, 2011)

stardancer said:


> This split also applies to capital gains/losses. My husband and I split all the investments this way


Perfect, thanks.


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## newfoundlander61 (Feb 6, 2011)

All of the money used to invest is 100% from the sale of our joint home, and is all in one joint account. No other money has been added to the account.


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## agent99 (Sep 11, 2013)

newfoundlander61 said:


> All of the money used to invest is 100% from the sale of our joint home, and is all in one joint account. No other money has been added to the account.


We had the discussion about setting up the accounts some time ago. What pwm says is accurate. 

But many couples just don't do that and it seems CRA don't get after them. It might have been easier to ensure your 50% remains correct by having two joint accounts. But you should be OK. Just keep records and spend more cash flow from the higher earner if you eventually deposit separate incomes into the joint account, like for example RRIF withdrawals.


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## AltaRed (Jun 8, 2009)

Newfoundlander61 is just fine at 50/50 given these are funds from the sale or a PR, i.e. marital home.


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## gibor365 (Apr 1, 2011)

AltaRed said:


> Newfoundlander61 is just fine at 50/50 given these are funds from the sale or a PR, i.e. marital home.


All those "attribution rules" are so confusing... For example, when 20 years ago we bought out house, about 80% of cash payment was from my income (we brought cash to Canada from Israel where 90% of our cash was from my income, my wife was a student there and worked only 1 year). Now, I'm retired and my wife is working and have 200K+ income per year. In a couple of years we plan to sell our house and invest money somewhere. Logically 80% of income from invested from house sold money should be attributed to me, but I have a feeling that CRA won't like it as my wife is in the highest tax bracket and I'm in the lowest.


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## pwm (Jan 19, 2012)

AltaRed said:


> Newfoundlander61 is just fine at 50/50 given these are funds from the sale or a PR, i.e. marital home.


I agree based on the fact that when a marriage dissolves, the wife can claim 50% of the value of the house even if she paid nothing toward the place. It's happened to my brother in law 3 times. That should have been another of my bullet points. Didn't think of that one.


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## AltaRed (Jun 8, 2009)

gibor365 said:


> All those "attribution rules" are so confusing... For example, when 20 years ago we bought out house, about 80% of cash payment was from my income (we brought cash to Canada from Israel where 90% of our cash was from my income, my wife was a student there and worked only 1 year). Now, I'm retired and my wife is working and have 200K+ income per year. In a couple of years we plan to sell our house and invest money somewhere. Logically 80% of income from invested from house sold money should be attributed to me, but I have a feeling that CRA won't like it as my wife is in the highest tax bracket and I'm in the lowest.


If it is the marital home and is held in joint undivided interest (with no specifics on beneficial interest to the contrary), it will almost certainly ALWAYS be considered 50/50 regardless of who has contributed to it, etc, etc. Just one of those things......


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## newfoundlander61 (Feb 6, 2011)

Thanks for the good info, taxes done a efiled this afternoon.


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## Onagoth (May 12, 2017)

newfoundlander61 said:


> Received my first T5 this year due to dividends paid in Nov from RY, as the the account is joint (both our names on the top portion of T5) and both our money from house sale do I simple divide the numbers from boxes 24-26 on the T5 and enter them into each of our returns. Slip has my SSN on it but I was expecting that anyway. Thanks for any info. As this is my initial T5 reporting I want to be consistent in my tax filing going forward as the T5's increase. At some point I will sell a holding and was also wanting to know if this way of reporting the T5's can be used for any capital gains as well in the future. Wouldn't dare call CRA as I would be on hold for days this time of the year  Thanks for any help with this.
> 
> Paul


50/50 is a reasonable split for JWROS....had you held these securities jointly as tenants in common there is more opportunity to use a different allocation.


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## Onagoth (May 12, 2017)

gibor365 said:


> All those "attribution rules" are so confusing... For example, when 20 years ago we bought out house, about 80% of cash payment was from my income (we brought cash to Canada from Israel where 90% of our cash was from my income, my wife was a student there and worked only 1 year). Now, I'm retired and my wife is working and have 200K+ income per year. In a couple of years we plan to sell our house and invest money somewhere. Logically 80% of income from invested from house sold money should be attributed to me, but I have a feeling that CRA won't like it as my wife is in the highest tax bracket and I'm in the lowest.


Attribution rules are simple in theory.....where it comes really complicated is when taxpayers intentionally trigger the attribution rules to produce a tax benefit and then the CRA argues GAAR.

There was a very interesting court case about that years ago.


You really don't need to be worried about the home though....if you lived there you the sale ought to qualify under the principle residence exemption.


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## gibor365 (Apr 1, 2011)

> Attribution rules are simple in theory.


 It's not simple in theory either. For example, for several years one spouse may have much higher income than other, and in other several years 2nd spouse has much higher income. Go figure out how to calculate attribution % hence interest is rolling from year to year.
In Canada every family is CRA hook, it's just impossible to calculate


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## AltaRed (Jun 8, 2009)

gibor365 said:


> It's not simple in theory either. For example, for several years one spouse may have much higher income than other, and in other several years 2nd spouse has much higher income. Go figure out how to calculate attribution % hence interest is rolling from year to year.
> In Canada every family is CRA hook, it's just impossible to calculate


Pffft! Attribution rules are clear and simple enough. Keep individual INVESTMENT finances separated in the appropriate individual or JTWROS accounts, and the tax slips speak for themselves, without ANY calculations. Contribute to household operating expenses as one likes, e.g. proportionate or disproportionate, because they are money out the door anyway, and CRA does not care. If the marital home titled is in joint, undivided interest, beneficial ownership is 50/50 regardless of who funds it.

Three simple rules. How complicated is that?


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## gibor365 (Apr 1, 2011)

AltaRed said:


> Pffft! Attribution rules are clear and simple enough. Keep individual INVESTMENT finances separated in the appropriate individual or JTWROS accounts, and the tax slips speak for themselves, without ANY calculations. Contribute to household operating expenses as one likes, e.g. proportionate or disproportionate, because they are money out the door anyway, and CRA does not care. If the marital home titled is in joint, undivided interest, beneficial ownership is 50/50 regardless of who funds it.
> 
> Three simple rules. How complicated is that?


It's only simple if every spouse has IND accounts (nice family arrangement, eh?!). In JTWROS accounts, it's not simple at all, as I constantly move different portion of money from bank to bank (to get better rate) and deposit to HISA and buy GIC. Except this, income (salary) of spouses can be very different from year to year, esp if one of the spousals retires...thus we have investment income from existing for years capital and new , current year income.


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## AltaRed (Jun 8, 2009)

Fair enough if one has already tangled up finances. Accounting retroactively is near impossible. 

Hindsight, but one should have kept separate JTWROS accounts from the beginning to keep all assets 100% yours, or 100% hers. We've had this conversation before... about JTWROS accounts. Have 2 of them with certain FIs, one named "His and Hers" with 100% of the investments "His" and the other named "Hers and His" with 100% of the assets "Hers". It then makes no difference whose income is much higher in any given year. They contribute accordingly to "their" own investment accounts that given year. 

Works the same way in inverse when one retires and the other does not. The working spouse contributes to his/her own specific JTWROS account, and the retired spouse may be pulling capital from his/her own investment account. 

Nothing complicated about either of those scenarios nor does it handicap moving money from bank to bank. Just move it from the right JTWROS account to the right JTWROS account.


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## gibor365 (Apr 1, 2011)

> Fair enough if one has already tangled up finances. Accounting retroactively is near impossible.


 That what I'm talking about.



> one should have kept separate JTWROS accounts from the beginning to keep all assets 100% yours, or 100% hers.


 if we were supposed to start investing now, we would do it..... but when you are an immigrant , you have no idea of those very specific rules, hence AFAIK , no other country in the World has those attribution rules .... moreover, except US and Canada, employees are not filing taxes at all, everything is done automatically by revenue agency. 
btw, first several years after coming to Canada, 3 different accountants were doing taxes for us and they simply attributed All T5's to spouse who had the lowest income. Then I started to file taxes by myself and now simply attribute T5 from joint accounts 50/50 and for IND to respective recipient. 
Thus, whatever we do now, CRA can always come after us, and it would be 100% impossible to establish how income to be split as per attribution rules.
P.S. Also, it's very common among immigrant families to have joint accounts with their parents, as vast majority of them sponsored and for 10 years cannot get any assistance from the government. So, from time to time, we deposit out money to our parents account... and if even we'd be calculating all contributed $, we don't even have option to split income with parent (only with spouse).


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## AltaRed (Jun 8, 2009)

Joint accounts with parents? Why not just gift the money and keep finances separated? Unintended consequences compound exponentially with the number of joint owners.

The only significant opportunities to legally split income with spouses is via spousal loans, spousal RRSPs, and pension income splitting. Some CCPC's do it distributing dividends to spouses and adult children to some degree, but I believe the gov't has squeezed that gaping loophole significantly....as they should. There has been a lot of debate about individual based tax reporting vs filing jointly such as in the USA. The latter disproportionately benefits couples with one disproportionately high earning spouse. Not sure that is socially fair despite the fact I would have benefited extremely well personally from such a system over 3+ decades.


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## gibor365 (Apr 1, 2011)

AltaRed said:


> Joint accounts with parents? Why not just gift the money and keep finances separated? Unintended consequences compound exponentially with the number of joint owners.
> 
> The only significant opportunities to legally split income with spouses is via spousal loans, spousal RRSPs, and pension income splitting. Some CCPC's do it distributing dividends to spouses and adult children to some degree, but I believe the gov't has squeezed that gaping loophole significantly....as they should. There has been a lot of debate about individual based tax reporting vs filing jointly such as in the USA. The latter disproportionately benefits couples with one disproportionately high earning spouse. Not sure that is socially fair despite the fact I would have benefited extremely well personally from such a system over 3+ decades.


Alta, it's not only in US , but also in Germany and any other developed countries.
I just don't see any logic why family where both spouses earn 50/50 should pay twice less tax than family where spouses earn 90/10! Hence both those families have same budget. It's like corporation is paying tax not a corporation , but every separate department pay own corporate tax depending on the income. imho, it's just stupid. 



> The only significant opportunities to legally split income with spouses


 I hope very much that Cons gonna win next election and Shreer would introduce income split like Harper did



> Joint accounts with parents? Why not just gift the money and keep finances separated?


 Can you please expand on this topic? Should it be some official certified document that I give gift in $$ to my mother ? The truth is that I give cash to my mom, my wife to her mom .... as really, they wouldn't survive without out support and I'm concerned that CRA can screw us 

P.S. All accounts with our moms are joint, because they cannot communicate on the phone with banks


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## AltaRed (Jun 8, 2009)

gibor365 said:


> I hope very much that Cons gonna win next election and Shreer would introduce income split like Harper did


I doubt it. It was seen as a windfall for the 'rich' and Harper took heat on it (spin from the Liberals). We have too many Canadians who believe in a race to the 'lower middle class'. A 'cut' in the 22% rate went over a lot better since it was slightly more inclusive.


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## gibor365 (Apr 1, 2011)

AltaRed said:


> I doubt it. It was seen as a windfall for the 'rich' and Harper took heat on it (spin from the Liberals). We have too many Canadians who believe in a race to the 'lower middle class'. A 'cut' in the 22% rate went over a lot better since it was slightly more inclusive.


Maybe yes, maybe no - but the fact that all developed countries allowed to split income , and not up to 2K as Harper did, but 100%

It's also beneficial for lower middle class, as family with one spouse earn 60K and other 0, would pay much lower taxes


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## AltaRed (Jun 8, 2009)

gibor365 said:


> Maybe yes, maybe no - but the fact that all developed countries allowed to split income , and not up to 2K as Harper did, but 100%


I don't think we know that for sure, but regardless, most Canadians, me included, really don't care what other countries do. Overall, considering ALL taxes, we are a relatively low tax jurisdiction in the OECD. We've had that conversation before too

This chart, though tainted by the commie Broadbent Institute, at least puts some perspective on it https://www.huffingtonpost.ca/2017/06/04/taxes-canada_n_16950242.html

Point being: We have no basis to be bitching!


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## Retiredguy (Jul 24, 2013)

gibor365 said:


> That what I'm talking about.
> 
> if we were supposed to start investing now, we would do it..... but when you are an immigrant , you have no idea of those very specific rules, hence AFAIK , no other country in the World has those attribution rules .... moreover, except US and Canada, employees are not filing taxes at all, everything is done automatically by revenue agency.
> btw, first several years after coming to Canada, 3 different accountants were doing taxes for us and they simply attributed All T5's to spouse who had the lowest income. Then I started to file taxes by myself and now simply attribute T5 from joint accounts 50/50 and for IND to respective recipient.
> ...


Attribution rules only apply to spouses and children under the age of majority. If you want to give (after tax) money to your parents to invest, it is perfectly legal as long as it is in their name alone. (meaning that you have given up any legal claim to the money) Same with adult children. The future investment proceeds from the gift will then be legally reported by the parents or adult children.


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## gibor365 (Apr 1, 2011)

AltaRed said:


> I don't think we know that for sure, but regardless, most Canadians, me included, really don't care what other countries do. Overall, considering ALL taxes, we are a relatively low tax jurisdiction in the OECD. We've had that conversation before too
> 
> This chart, though tainted by the commie Broadbent Institute, at least puts some perspective on it https://www.huffingtonpost.ca/2017/06/04/taxes-canada_n_16950242.html
> 
> Point being: We have no basis to be bitching!


Alta, don't talk for most Canadians. "the commie Broadbent Institute" doesn't take into consideration that in all EU countries high education is free, as an example and there are 100% family income split.

Also it was funny to see that this chart shows that Estonia has higher tax.... from another article
_According to this year’s International Tax Competitiveness Index, Estonia has the most competitive tax system in the developed world.

Key drivers for Estonia’s high rank are its relatively low corporate tax rate at 21 percent with no double taxation of dividend income, a nearly flat 21 percent income tax rate, a property tax that only taxes the value of land and not the value of building and structures, and a territorial tax system that exempts 100 percent of foreign profits._
https://taxfoundation.org/estonia-has-most-competitive-tax-system-oecd/


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## gibor365 (Apr 1, 2011)

Retiredguy said:


> Attribution rules only apply to spouses and children under the age of majority. If you want to give (after tax) money to your parents to invest, it is perfectly legal as long as it is in their name alone. (meaning that you have given up any legal claim to the money) Same with adult children. The future investment proceeds from the gift will then be legally reported by the parents or adult children.


Can you please provide link? I've never heard about it


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## Retiredguy (Jul 24, 2013)

gibor365 said:


> Can you please provide link? I've never heard about it


https://www.mondaq.com/about.asp

Go to the above website (tax lawyers) and search "attribution". They have several good articles.

Also https://ca.rbcwealthmanagement.com/...ttribution+rules.pdf/269e09e6-ce29-4a3a-a48d- 204884dc789a


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## AltaRed (Jun 8, 2009)

gibor365 said:


> Alta, don't talk for most Canadians. "the commie Broadbent Institute" doesn't take into consideration that in all EU countries high education is free, as an example and there are 100% family income split.
> 
> Also it was funny to see that this chart shows that Estonia has higher tax.... from another article
> _According to this year’s International Tax Competitiveness Index, Estonia has the most competitive tax system in the developed world.
> ...


None of that matters to most Canadians. For those that gripe and whine and moan, they can always emigrate. Also, most Canadians don't even know where Estonia is, so what is the point? 

Our tax system has indeed been complicated by political machinations and contamination resulting from vote getting promises, but the tax burden is better than many places, including the USA where I have completed more than my share of 1040s and state income tax filings in the past.

P.S. Canada does not double tax dividends either, i.e. that is why we have the Dividend Tax Credit, to compensate for the corporate income tax previously paid.


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## AltaRed (Jun 8, 2009)

gibor365 said:


> Can you please provide link? I've never heard about it


Lots of articles simply by googling "income attribution rules summary". This is a well covered topic from a lot of sources. With some basic guidelines, it is not really all that complex.


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## gibor365 (Apr 1, 2011)

> Also, most Canadians don't even know where Estonia is, so what is the point?


 It's true, but sad , as those Canadians have no idea about system (frequently better) than here. But all Canadians heard that Canada "is the best country in the World". . I took a look at this graph and Estonia caught my eyes and my point that those graphs are "fake news" .

btw, Canada has around 50 tax forms (T's and Releve's). While working I was submitting them to CRA and MRQ .... this is just insane!


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## AltaRed (Jun 8, 2009)

Ignorance is sometimes bliss. Just ask Americans who are way down the scale from us (I've lived there almost a total of 10 years and seen it over and over again). Maybe our problem is we compare ourselves to Americans rather than to Europe, but that is mostly a result of geography. My opinion still stands though. Quit complaining.


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## gibor365 (Apr 1, 2011)

AltaRed said:


> Ignorance is sometimes bliss. Just ask Americans who are way down the scale from us (I've lived there almost a total of 10 years and seen it over and over again). Maybe our problem is we compare ourselves to Americans rather than to Europe, but that is mostly a result of geography. My opinion still stands though. Quit complaining.


I agree that "our problem is we compare ourselves to Americans rather than to Europe"! and I agree that tax system in US is also huge mess that Trump at least trying to improve.



> For those that gripe and whine and moan, they can always emigrate.


 Cannot because of the family reasons and CRA would never let us "cut ties" with Canada as only our income tax about 150K and a lot of $$$ in registered accounts that we cannot touch. SO, just trying to change the system.
But if Alberta separated from Canada, we may move there


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## Eclectic12 (Oct 20, 2010)

gibor365 said:


> ... Cannot because of the family reasons and CRA would never let us "cut ties" with Canada as only our income tax about 150K and a lot of $$$ in registered accounts that we cannot touch. SO, just trying to change the system ...


Cutting ties properly takes CRA out of the picture from what others have posted. As non-residents, they seem to have no issue getting $$$ paid to them from their registered accounts.

On what grounds would you anticipate CRA arguing you are still a Canadian tax resident, after emigrating/cutting ties?


Cheers


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## AltaRed (Jun 8, 2009)

Agreed that access to registered accounts easily available to non-residents (and non-residents for tax purposes), albeit that may be more doable with brokerages than other FIs which often don't have a clue about what they are doing. Financially, the primary thing that needs to be done by people emigrating is to pay the cap gains tax bill for appreciated assets in taxable accounts, and obviously to provide a foreign mailing address so that the FI knows one is a non-resident for tax purposes. The cap gains bill is totally justifiable for the rewards reaped while a resident of Canada. 

There really are not a lot of constraints about 'leaving' Canada on a 'permanent' basis. The issues are more family and social ties as Gibor has articulated somewhat. Trying to change the system is through our voting process and engaging in 'public consultations' when such are offered to the public, not that single voices make one iota of a difference. I've made submissions to OSC, CSC et al from time to time when they've asked for public comment. Albeit that has nothing to do with the tax system.


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## Eclectic12 (Oct 20, 2010)

You wouldn't recommend something like the Canadian Taxpayers Federation?


Cheers


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## AltaRed (Jun 8, 2009)

Maybe, but my initial reaction is the CTF complains about everything and that undermines credibility. No gov't official wants to hear complaints about 'everything' and if I was in the Dept of Finance, I think I'd tune them out most of the time.

Lobby groups need to be more targeted and rationale in their approach. One of the very worst I've ever seen at any time anywhere is CARP. It is always 'more...more...more' for seniors when Canadian seniors, with the exception of the lowest income types needing more social support, are the most pampered and catered too demographic in Canada. It should be an embarrassment.


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## gibor365 (Apr 1, 2011)

> There really are not a lot of constraints about 'leaving' Canada on a 'permanent' basis. The issues are more family and social ties as Gibor has articulated somewhat.


Yeap, that's true. Registered accounts also can be a problem. When some time ago we were offered to relocate to US and called and talked with CRA .... The problem that there is no actual rules if you can or cannot cut ties, you have to fill out huge questionnaire and submit to CRA and they will decide to grant you such "priviledge" or not


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## AltaRed (Jun 8, 2009)

Tax treaties take care of most of those things, e.g. where do you have your primary ties? In cases where an individual has re-located out-of-country, has his/her dependents with him/her, has a DL and health care in that new country, a residential lease or a home, and potentially employment in that new country, it is virtually guaranteed that person is no longer a resident of Canada for tax purposes. I've done this 3 times on ex-pat assignments to the USA. Have never filled out the NR73 form in those instances, and yet kept all my financial accounts in Canada intact during that time (bank, brokerage, RRSP).


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## gibor365 (Apr 1, 2011)

AltaRed said:


> Tax treaties take care of most of those things, e.g. where do you have your primary ties? In cases where an individual has re-located out-of-country, has his/her dependents with him/her, has a DL and health care in that new country, a residential lease or a home, and potentially employment in that new country, it is virtually guaranteed that person is no longer a resident of Canada for tax purposes. I've done this 3 times on ex-pat assignments to the USA. Have never filled out the NR73 form in those instances, and yet kept all my financial accounts in Canada intact during that time (bank, brokerage, RRSP).


We will consider it in several years... Our daughter wants to go to medical school, in Israel she will be studying for free and programs are compatible to the best US universities and we will be exempt from any foreign taxes for 10 years as returned citizens


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## kcowan (Jul 1, 2010)

AltaRed said:


> Maybe, but my initial reaction is the CTF complains about everything and that undermines credibility. No gov't official wants to hear complaints about 'everything' and if I was in the Dept of Finance, I think I'd tune them out most of the time.
> 
> Lobby groups need to be more targeted and rationale in their approach. One of the very worst I've ever seen at any time anywhere is CARP. It is always 'more...more...more' for seniors when Canadian seniors, with the exception of the lowest income types needing more social support, are the most pampered and catered too demographic in Canada. It should be an embarrassment.


Yes I agree. Both CTF and CARP are one-track in their pursuit of issues. I selectively participate in CTF but I never support CARP. It is so blatant and claims credit for initiatives that happened to support their agenda.


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## Eclectic12 (Oct 20, 2010)

AltaRed said:


> gibor365 said:
> 
> 
> > ... Registered accounts also can be a problem. When some time ago we were offered to relocate to US and called and talked with CRA .... The problem that there is no actual rules if you can or cannot cut ties, you have to fill out huge questionnaire and submit to CRA and they will decide to grant you such "priviledge" or not
> ...


+1 ... the issues I have heard of are when someone made mistakes, typically keeping residential ties (significant or secondary) or assuming having a job out of country with a long absence automatically meant being a non-resident.

For the US, the common RRSP issues I can recall were either moving to a state that taxes RRSPs or failing to sell/re buy as only the cost base is allowed to be withdrawn, US tax exempt. The TFSA is US taxes as well as requires FBAR reporting so keeping it is an issue. https://www.theglobeandmail.com/glo...er-before-you-move-to-the-us/article21934012/


Having relatives/friends like AltaRed who had no issues changing from Canadian tax resident to non-resident on date they departed Canada, the idea that it's CRA's decision to randomly make - no matter what one has done strikes me as strange.

Cheers


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## AltaRed (Jun 8, 2009)

Tax treaties are intended to minimize, if not eliminate, double taxation AND to provide tie breakers in case both gov'ts try to claim the taxpayer as their own. Tax authorities back off when the tie breakers are presented to them.


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