Mr Valone Is a U

Essay

Mr. Valone is a U.S. citizen. However, since obtaining permanent residence status in 2006, he has been employed on a full time basis in London, Ontario. His employer is a Canadian subsidiary of a multi-national corporation that operates in a number of different countries. The head office of the company is in the United States.
Mr. Valone has been very successful in his position with the Canadian subsidiary. Based on this, he has been offered a promotion which involves a significant increase in salary. However, this promotion is conditional on his moving to the company's head office in Philadelphia no later than March 1, 2020. Given the sizable increase in remuneration, Mr. Valone finds this offer too good to pass up.
As he is a U.S. citizen, he has no difficulty getting the appropriate documentation to establish his residency in the U.S. He relinquishes his Canadian driver's licence, as well as his provincial health care card. As required by his employer, he is at his desk in the new work location in the U.S. on March 1.
Mr. Valone and his spouse have two children who are attending a private school in London. The current semester at this school lasts until June 15, 2020. In order to provide continuity in their education, Mrs. Valone decides that she and children will remain in Canada until the current semester is finished. They depart on June 20, 2020.
The real estate market in London has been somewhat slow of late. As a consequence, the Valone's house is not sold until October 5, 2020.
Required: For purposes of assessing Canadian income taxes, determine when Mr. Valone ceased to be a Canadian resident and the portion of his annual income which would be assessed for Canadian taxes. Explain your conclusions.