SELECTED US TAX DEVELOPMENTS

Abstract

Canadians who emigrate to the United States or elsewhere face many decisions and considerations associated with departure, but careful tax planning should not be an afterthought. When an individual ceases to be resident in Canada, the individual is deemed to dispose of all of the individual’s property (subject to certain listed exceptions) for fair market value proceeds immediately before departure and is required to pay Canada’s departure tax on the deemed disposition. This tax presents an opportunity for the individual to step up the US tax basis in the property under the US-Canada treaty.