When a person becomes a Canadian resident for tax purposes,
that person will become subject to Canadian tax on that
person's world income from the time Canadian residence is
obtained.
In the case of an individual, the taxation year of immigration
is, in effect, divided into two parts: the part during which
the individual was a non-resident; and the part during which
the individual was Canadian resident. It is only the worldwide
income that is earned during the second part that is subject
to Canadian tax. Income earned during the first part of
that year will generally only be subject to Canadian tax
if it is derived from Canadian sources.
During the year of immigration normal personal tax credits
allowed ("personal amounts") are pro-rated based upon the
portion of the calendar year during which the individual
was resident in Canada.
Capital property owned at the time of immigration is generally
deemed to have a cost for Canadian tax purposes equal to
the fair market value of such property on the date that
Canadian residency is obtained. The main exception to this
rule is the fact that it does not apply to "taxable Canadian
property" ("TCP"). The most commonly encountered forms of
TCP are real property situated in Canada and shares in private
corporations resident in Canada.
For non-residents with significant wealth and/or sources
of income it is generally advisable to seek Canadian tax
advice before immigration to Canada in order to take steps
to minimize the impact of Canadian taxation.
One of the most commonly used planning techniques for
immigrants to Canada who have significant wealth is the
formation of an "immigrant trust" in a tax-haven jurisdiction.
If properly structured, this will allow investment income
earned during the first 60 months of Canadian residency
to be exempt from Canadian taxation.