Sunday, October 19, 2008
Jack Bernstein (Aird & Berlis, Toronto) & Ron Choudhury (Aird & Berlis, Toronto) have published Tax Planning for Immigration to Canada, 52 Tax Notes Int'l 151 (Oct. 13, 2008). Here is part of the Introduction:
This article deals with the special considerations for U.S. executives who are transferred to Canada for less than five years, U.S. citizens immigrating to Canada who wish to give up their U.S. citizenship, and U.K. non-doms wishing to relocate to Canada as permanent residents. The article also reviews the Canadian tax implications when a nonresident transfers non-Canadian assets to a nonresident trust for his family before immigrating to Canada (an immigration trust). An immigration trust can provide significant tax savings since the trust and the beneficiaries will not be subject to Canadian tax on income or capital gains earned or realized outside of Canada for the first 60 months of Canadian residency.