An individual’s decision to leave Canada can trigger immediate Canadian tax consequences, even when no assets are actually sold. The deemed disposition rules may create significant departure tax on investment portfolios, private-company shares and other appreciated property. However, the ultimate tax cost may depend heavily on decisions made before departure.

This intermediate-to-advanced course focuses on the planning decisions practitioners should evaluate before an individual ceases Canadian tax residency. Participants will examine how planning considerations such as the timing of departure, realization of gains and losses, use of the Lifetime Capital Gains Exemption, departure-tax deferral, asset retention and foreign tax coordination can affect the overall result.

The course begins with a concise review of residency cessation and the deemed disposition framework, but the primary emphasis is on evaluating planning alternatives, identifying competing tax considerations and developing an integrated departure strategy. Examples are used to illustrate how the rules apply in practice.

Pre-requisite: None

Upon completion of this course, participants will be able to:

• Identify when an individual is likely to cease Canadian tax residency and why the departure date matters.
• Determine which assets may create significant departure-tax exposure.
• Compare alternative strategies for realizing, deferring or managing accrued gains before departure.
• Evaluate the use of capital losses, the Lifetime Capital Gains Exemption and other available tax attributes.
• Assess planning considerations involving private-company shares, investment portfolios, real estate, stock compensation and registered plans.
• Evaluate whether a departure-tax deferral election is appropriate.
• Identify potential double-taxation concerns and coordinate Canadian planning with the destination country’s tax rules.
• Develop a practical pre-departure planning checklist and implementation plan.