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.

• Canadian CPAs in public practice preparing or reviewing T1 returns for individuals with foreign investments. 
• Tax practitioners advising high-net-worth individuals and owner-managers on international reporting obligations. 
• Cross-border tax practitioners, financial advisors and tax lawyers who work with Canadian residents holding foreign investments. 
• CPA students and newly designated CPAs looking to expand into international tax compliance.

Canadian CPAs, tax practitioners and advisors involved in personal tax, cross-border tax or international mobility. Also suitable for lawyers, financial planners and other professionals advising individuals leaving Canada.

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.

Module 1 — Establishing the Departure Date and Identifying Planning Exposure
This module establishes the foundation for departure planning and identifies the facts that must be resolved before meaningful planning can occur.

Topics

• Determining when Canadian tax residency ends
• Residential ties and treaty residence
• Timing differences between physical relocation and tax emigration
• Selecting and supporting the departure date
• Short-term assignments versus permanent relocation
• Split-year Canadian taxation
• Overview of the deemed disposition regime
• Property generally subject to departure tax
• Important exclusions from deemed disposition
• Taxable Canadian property retained after departure
• Fair market value and valuation-date considerations
• Creating a departure-tax exposure schedule
• Materiality and prioritization of planning issues
  
  

Module 2 — Pre-Departure Planning for Investments, Losses and Private Wealth
This module examines the principal strategies available to manage the individual’s accrued gains and investment assets before departure.

Topics
Managing capital gains and losses

• Comparing an actual sale with a deemed disposition
• Realizing gains before departure
• Delaying gains until after departure
• Crystallizing accrued losses
• Superficial-loss and affiliated-person considerations
• Applying current-year and carried-forward capital losses
• Foreign-exchange gains and losses
• Donation of appreciated securities before departure
• Asset transfers between spouses
• Rebalancing investment portfolios before emigration
• Retaining versus disposing of Canadian investments
  
  

Private-company shares

• Valuing shares of a CCPC or other private corporation
• Potential use of the Lifetime Capital Gains Exemption
• Purification before departure
• Crystallizing the exemption
• Estate-freeze and share-reorganization considerations
• Shareholder loans and extraction of corporate funds
• Retaining a Canadian corporation after departure
• Future dividend and disposition consequences
• Risks of completing restructuring too close to departure
  
  

Other private-wealth considerations

• Foreign private-company shares
• Partnership interests
• Trust interests
• Life insurance and investment contracts
  
  

Module 3 — Asset-Specific Planning, Deferral and Cross-Border Coordination
This module examines assets that do not fit neatly into a standard investment-portfolio analysis and considers how Canadian departure planning interacts with the destination country.

Topics
Departure-tax deferral

• Purpose of the deferral election
• Comparing immediate payment with deferral
• Liquidity considerations
• Security requirements
• Interest and administrative implications
• Subsequent disposition of deferred property
• Monitoring and compliance obligations
• Situations where deferral may be unattractive

Real estate

• Canadian principal residence
• Canadian rental and investment property
• Foreign real estate
• Property excluded from departure tax but taxable later
• Change-in-use and principal-residence planning
• Retaining Canadian real estate as a non-resident
• Future withholding and non-resident filing considerations
  
  

Registered and deferred arrangements

• RRSPs and RRIFs
• TFSAs
• RESPs and FHSAs
• Pension and deferred compensation plans
• Employee stock options
• Restricted share units and other equity compensation
• Timing employment-related income before or after departure
  

Foreign tax and treaty coordination

• Potential mismatch between Canada’s deemed disposition and the destination country’s tax basis
• Future foreign tax credits
• Double-taxation risk
• Departure to the United States versus another country
• Coordinating Canadian and foreign advisors
• Avoiding planning that produces a Canadian benefit but a larger foreign tax cost
  

Common Planning Failures

• Advising the client only after departure
• Focusing solely on the departure-tax calculation
• Ignoring accrued capital losses
• Missing an opportunity to use the Lifetime Capital Gains Exemption
• Retaining assets without considering future non-resident taxation
• Deferring tax without considering liquidity, security or monitoring requirements
• Failing to coordinate Canadian and foreign cost bases
• Choosing a departure date without modelling alternatives
• Completing a corporate reorganization without sufficient lead time
• Overlooking the possibility that the individual may later return to Canada

Course Content Created: September 2026

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About This Product

CPABC On-Demand Courses offer self-paced learning through recorded sessions from previously delivered live seminars. Where available, accompanying materials such as handouts or course notes are included. On-demand courses are eligible for verifiable CPD hours upon successful completion, and a certificate will be made available for download for your records.

Please note that not all on-demand courses include downloadable materials such as handouts, course notes or presentation slides.

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