Becoming Non-Resident: Leaving Canada
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A practical guide for Canadian CPAs supporting clients who leave Canada.
Michael Cadesky guides CPAs through the core challenges clients face when leaving Canada, highlighting how to sever residential ties, apply treaty tie-breaker rules, and navigate the tax consequences of the deemed disposition on departure.
Course Overview
The seminar also explores the tax consequences in the foreign country and the ways those rules interact with Canada’s system. Topics include the treatment of retirement plans, ownership of Canadian corporations, withdrawals from corporate structures and trusts, and exposure to double taxation. Throughout the program, CPAs gain a structured understanding of the technical requirements and the planning opportunities available before and after departure.
Seminar Snapshot
Becoming Non-Resident: Tax Rules & Risks
You will then examine the tax rules triggered upon departure, including the deemed disposition of capital property, the availability of the principal residence exemption, the application of TOSI to certain shares, and the treatment of interests in Canadian resident trusts. The program continues with post-departure taxation of retirement plans, corporate distributions, and trusts, with emphasis on withholding tax regimes and planning techniques such as corporate redemptions, capital dividend strategies, RCAs, and conversion of corporate structures before relocating. To complete the picture, the course outlines how foreign taxation can interact with Canadian rules, the potential for double taxation, and the importance of early planning for estate tax, investment structures, and foreign FAPI-type systems.
- Determining when a client has sufficiently severed residential ties to Canada
- Applying treaty residency tests and advising on their practical implications
- Guiding clients on withholding tax rules for RRSPs, RRIFs, pensions, and corporate shares
- Recognizing the impact of foreign tax systems on Canadian assets and income streams
- Advising on the use of RCAs, trust distributions, and structure adjustments before departure
- Advising clients who are relocating, retiring abroad, or returning to their home country
- Planning corporate share redemptions, reorganizations, or withdrawals for emigrating owners
- Managing cross-border tax exposures for individuals with multi-jurisdictional assets
- Supporting clients with RRSPs, RRIFs, pensions, or Canadian trusts after they leave Canada
Meet Your Presenter
Michael Cadesky
Michael Cadesky is the managing partner at Cadesky Tax and a committed contributor to the tax and accounting professions since 1980, earning the title of Fellow from CPA Ontario. He is a past governor of the Canadian Tax Foundation, past chair of STEP Canada and STEP Worldwide, and past chair of the CPA Canada Tax Committee for Small and Medium-Sized Enterprises. Michael is also the co-author of 11 books on tax subjects and the author or co-author of numerous papers and articles on Canadian and international taxation.
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This is a first time for me as well. Your firm was recommended to by one of my friends. Great source of information.
Thank you Mike, Hugh and team! I enjoyed the practical and realistic solutions to various tax issues.
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Thank you for the wonderful presentation, materials, and handling of queries as always.
This is my first time taking the Cadesky Tax Seminars. I am learning a lot and watching archived courses too. You have done a great job. Thank you so much!
I really enjoy your seminar series. Your presentations are extremely thorough and you explain complex tax issues very clearly.
The presentations are relevant. The material is easy to follow. Worked examples are excellent. It is a great value.

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