Retired living part time in Canada,

do I as a landed immigrant have to pay tax in canada if I pay
medical insurance here and only live here 6 months of the year
and 6 months in the U.S.? I file my U.S. income every year
david ingram replies:
To have a valid Canadian Provincial Medical insurance card, you
are supposed to be living (sleeping) in Canada more than 183
nights in the year.
If you are in Canada more than 183 nights in the year, you are
taxable in Canada
Since it is also imperative that you record your days in Canada
to keep your PR status and the card in force for your renewal
after five years, you will likely put yourself in a taxable
It sounds to me that you are married to a Canadian and he is
spending his time with you in the USA.  You have to look at
Article IV of the US / Canada Income Tax Convention (Treaty) to
make an absolute decision.
Article IV follows along with some other observations taken from
the US / Canada Taxation link at in first box on
right hand side of the page:
Article IV - Fiscal Domicile - (it is the same number in most
For the purposes of this Convention, the term "resident of a
Contracting State" means any person who, under the law of that
State, is liable to taxation therein by reason of that person's
domicile, residence, citizenship, place of management, place of
incorporation or any other criterion of a similar nature, but in
the case of an estate or trust, only to the extent that income
derived by the estate or trust is liable to tax in that State,
either in its hands or in the hands of its beneficiaries. For the
purposes of this paragraph, a person who is not a resident of
Canada under this paragraph and who is a United States citizen or
alien admitted to the United States for permanent residence (a
"green card" holder) is a resident of the United States only if
the individual has a substantial presence, permanent home or
habitual abode in the United states and that individual's
personal and economic relations are closer to the United states
than any other third State.  The term "resident" of a Contracting
State is understood to include:
(a) the Government of that State or a political subdivision or
local authority thereof or any agency or instrumentality of any
such government, subdivision or authority, and
(b) (i) A trust, organization or other arrangement that is
operated exclusively to administer or provide pension, retirement
or employee benefits, and
    (ii) A not-for-profit organization that was constituted in
that State, and that is, by reason of its nature as such,
generally exempt from income taxation in that State.
2. Where by reason of the provisions of paragraph 1 an individual
is a resident of both Contracting States, then his status shall
be determined as follows:
(a) he shall be deemed to be a resident of the Contracting State
in which he has a permanent home available to him. If he has a
permanent home available to him in both Contracting States, he
shall be deemed to be a resident of the Contracting State with
which his personal and economic relations are closer (centre of
vital interests);
(b) if the Contracting State in which he has his centre of vital
interests cannot be determined, or if he has not a permanent home
available to him in either Contracting State, he shall be deemed
to be a resident of the Contracting State in which he has an
habitual abode;
(c) if he has an habitual abode in both Contracting States or in
neither of them, he shall be deemed to be a resident of the
Contracting State of which he is a national;
(d) if he is a national of both Contracting States or of neither
of them, the competent authorities of the Contracting States
shall settle the question by mutual agreement.
Where by reason of the provisions of paragraph 1 a person other
than an individual is a resident of both Contracting States, the
competent authorities of the Contracting States shall by mutual
agreement endeavour to settle the question and to determine the
mode of application of the Convention to such person.
Notwithstanding the preceding sentence, a company that was
created in a Contracting State, that is a resident of both
Contracting States and that is continued at any time in the other
Contracting state in accordance with the corporate law in that
other Contracting State shall be deemed while it is so continued,
to be a resident of that other State.
You can see that the countries themselves have set it up so that
they will get tax. It is up to you to arrange your affairs to pay
the least tax possible.
Both Canada and the U.S. will tax you on any money you earn
within the country. The BIG question is:
Canada taxes on RESIDENCY, not citizenship. Basically, if you
have been in Canada for more than 183 days (counting the hours -
one hour is only one hour, not one day as in the States), you are
taxable on your world income, no matter where it is located and
under whose name you have your assets stashed away. That is why
Howard Hughes left Canada when he did back in the 70's. If he had
stayed in Canada (even as a visitor) two more days, he would have
been taxable on his world wide holdings.
Note that in March, 1999 Denise Rondpre of  Revenue Canada
Customs Excise and Income Tax issued a policy letter to Foreign
Air Crew flying for Canadian Airlines and Air Canada. This
directive stated that it was Revenue Canada's opinion that one
hour in Canada constituted a full day in spite of the fact that
the courts have ruled against them and the law, itself, has not
changed. I do not think that this is enforceable, but you must be
aware of it.
If you are in Canada for any period and earn more than $10,000,
you must pay tax on the total amount to Canada,  or vice versa if
a Canadian is in the U.S. Entertainers and sports figures are
exempt for up to $15,000 but they are to have 15% tax withheld
from their gross salaries or remuneration (including hotel rooms,
plane tickets, car rentals, meals, etc.). Remember that even
though the first $10,000 or $15,000 above is not "taxable", you
must file a return and quote the treaty article number
specifically to claim the exemption.  The U.S. has a minimum
$1,000 fine for failure to report the treaty number to claim the
exemption, even if there is no tax owing. In practical terms,
this means you only get fined if not taxable.  (Although this was
always here, Revenue Canada rarely enforced the rule.  In this
case the enforcement laws DID change in March, 1998 and the US
resident MUST file if working in Canada.)
Remember also, this refers to "where" the work is performed, not
where the money comes from.  Therefore, if you worked in San
Francisco for one month for your Canadian employer and were paid
$6,000 U.S. by Bell Telephone in Ontario, you would have to file
a California return reporting your world income and exempting the
amount earned in Canada and would have some tax to pay to
California on the $6,000.  On the Federal return, you would file
for an exemption under Article XV of the U.S. / CANADA Tax Treaty
and pay no federal tax to the U.S.  You would then claim a credit
for the California tax paid on your Canadian income tax return.
You should also get BELL to agree to pay the $400 to $1,000
accountant's bill to prepare these complicated tax returns.
The U.S. taxes on citizenship first and residency or physical
presence second. If you have another tax home, and are just an
extensive visitor in the States, you can escape U.S. tax on your
income from other countries. However, if you renounce your other
tax home or become a "green card" holder or are in the U.S. for
more than 183 days in one year, you are subject to U.S. income
tax on your world income.
The U.S. taxes its citizens and green card holders wherever they
are and no matter what they are doing. The U.S. taxes its
citizens in Canada and they will tax them in the North Sea. The
U.S. will add on the benefit of housing allowances, car
allowances, servants, and education allowances for people who
have not been in the U.S. for twenty years but who are still U.S.
citizens.  If you want the benefit of U.S. Citizenship, you pays
your taxes.) The first $70,000 U.S. of income earned from
personal  services (as opposed to capital) is exempt if you have
been out of the country for a full calendar year in one test or
for 330 out of 365 days in another test using a fiscal year.
However, being "exempt" does NOT mean that you do not have to
file a tax return. You must still file your U.S. 1040, report the
Canadian Earnings in U.S. dollars and claim the "up to $72,000
U.S." by filing a form 2555 with the 1040. If you have
rental, royalty, or any income other than from services, you must
also report the income in U.S. dollars.  Since you will have paid
tax to Canada first, you will file a Form 1116 with the 1040 to
claim your foreign tax credit. A separate Form 1116 must be filed
for each kind of income, i.e. rental, pension, dividends, etc.
The RRSP earnings may be exempted under ARTICLE XXIX.5 of the
U.S. / CANADA Income Tax Treaty 1980.
Social security (FICA) taxes usually do not have to be paid to
the U.S. under Article XXIX.4 of the U.S./CANADA Income Tax
treaty or Article V of the CANADA / U.S. Social Security
Agreement.  (I sure hope all this is impressing you).
Therefore, a U.S. citizen living in Canada who had a rental
house, a job, an RRSP, some dividends and some capital gains from
the sale of stock would file his or her Canadian return first and
then file a U.S. return with these forms:
* 1040 - is the basic return for a citizen or resident of the
U.S. or landed immigrant of the U.S. (commonly called a "green
card" holder).
* Schedule A - to claim itemized deductions if needed
* Schedule B - to report the dividend income
* Schedule D - to report the capital gains
* Schedule E - to report the rental income
* 4562 - to report depreciation on the rental house
* 1116 - (maybe two foreign tax credit forms) - one for any
income from services over
    $72,000, one for the rental, capital gains, and dividend
* 1116(AMT) - two more forms to calculate the foreign tax credit
for Alternative Minimum Tax purposes (AMT)
* 2555 - to exempt up to $72,000 U.S. of earnings from services
* 6251 - Alternative Minimum tax form
* FICA (Social Security) exemption - to exempt income from U.S.
* RRSP election forms to exempt income earned within the RRSP
from current U.S. income tax until withdrawal
* TDF-90 form(s) - to report foreign bank accounts including
Canadian RRSP accounts which are considered "foreign trusts" -
failure to file this form can result in up  to a $500,000 fine
PLUS up to five years in jail
He or she might also have to file either of the following two
specialty forms when he or she owns shares in corporations.
* 5471 form - If you are a U.S. citizen and 5% or more owner of a
Canadian corporation. Failure to file this form can create fines
of $1,000 every 30 days up to $25,000
* 5472 form - If you are a Canadian who owns a U.S. corporation -
failure to file this one has fines of up to $30,000 every 30
Even though you or your friend have not filed your U.S. return
for years, you have not necessarily "got away with it". At least
once every two weeks, a U.S. Citizen arrives "a little
distraught" because the IRS has caught up to them.
And the biggest problem is that they can tax you for many years,
whereas you might only be allowed to claim your exemptions and
credits for two or three years back.
For instance, In January, 1995,  I had a "new" U.S. citizen
client bring me a U.S. Tax bill for $194,000 for 1986, 1987, and
1988.  He had been "caught" because he had applied for a new
The tax was on the gross income he had received in those years
when he sold off a stock portfolio (remember the crash).
Although he made about $40,000 to start, he lost after the crash
and ended up $30,000 down.  A Canadian accountant told him he did
not have to file U.S. returns because he was living in Canada.
In another case, a lady who had come to see me ten years ago and
had gone to see someone else because (this is what she told me)
they had a fancier office, has suddenly received a rude
awakening.  She and her husband have been losing money on the
rental of a large apartment complex in Seattle.  The penalty for
not filing and reporting this rental income is up to $10,000 a
year for not filing on non-resident rentals and 30% of the gross
rent with no expenses allowed.  In this case the rent is over
$500,000 a year and the total penalty and tax could be $2,000,000
with interest.  The other accountant told her she did not need to
file if she was losing money.  I had quoted her $500 to do her
return ten years ago and told her she had to file the return.
The accountant with the fancier office told her she did not have
to file because she lost money.  (That advice is wrong in both
countries by the way). Even $1,500 a year would be cheaper than
the tax bill coming up.
If you are still claiming the protection and advantages of your
U.S. citizenship, do yourself a favour. Bring your U.S. income
tax returns up to date from 1987 to the present.
It is rare that you will have to pay tax to the States. Higher
Canadian tax rates mean that, with the exception of Capital
Gains, the exemptions and foreign tax credits "almost always" eat
up the U.S. tax.
If you do have Canadian Capital Gains, it is usually important
that you do very accurate calculations to determine the tax. If
you claim the $ 100,000 exemption in Canada, the U.S. does not
recognize it and will tax you anyway. Better to save the
exemption or in some cases restructure the deal. Restructuring
might be as mundane as selling a business for less purchase price
and taking more wages to remain as an advisor.
That takes care of the majority of U.S. Citizens in Canada. Now
to the Canadian "visitor" to the U.S. - note that these ten year
old "NEW RULES" mean that many "Canadian Snowbirds" are taxable
in the U.S. on their World Income, even though they are only in
the U.S. for four months a year.
What happens is that after three, four, five or ten years of
wintering in Florida, or Texas, or Arizona, or California, the
Canadian visitor joins clubs, buys property, attends meetings,
becomes active in a condo association and suddenly finds their
"CENTER (CENTRE) OF VITAL INTERESTS" is as much or more in the
U.S. as it is in CANADA. Under those circumstances, the U.S.
government has every right to tax you.
At the back of the book around page 156, I have reproduced the
April, 1994 edition of the CEN-TAPEDE newsletter for more
information on this.
Long Time Visitors
For long time visitors to the U.S., the IRS uses the 183 day rule
that entitles most countries to tax anyone present in the country
for more than 183 days. However, they are far harder on their 183
day rule than Canada is. The U.S. counts an "hour" as a "WHOLE
DAY". So, if you arrive in Hawaii at 10:50 PM, that is a day, and
if you leave at 1:00 AM, that is a day.
In addition, to arrive at the 183 days, the U.S. looks at the two
preceding years. You have to take 1/3 of the days you were
present in the U.S. in the preceding year and add it to this
year's days and then you have to take 1/6 of the days in the year
preceding that and add it to this year's days.
Soooooooo! if you were in the States for six months in 1998, that
counts as 1 month, or 30 days for 2000. If you were in the States
for three months in 1999, that counts as 1 month or 30 days for
2000. You are now limited to stay in the States for 120 (maybe
122) days in 2000, after which you become taxable on your world
income unless you can show a tax home in another country (as in
the treaty provisions above). There is a form called an 8840 that
you may file to claim exemption from this if you can show that
your closer connection is to Canada.
This is tough to do however. As I was writing this little part on
Sept 29, 95, I received a call from a 55 year old man in Alberta.
He has a home in Canada, is retired already and spends the
winters golfing at his golf course condominium in Arizona.   In
Arizona, he golfs, plays cards, goes to church and visits with
friends in the same golf course country club estate.  In Canada,
he visits his kids in B.C. and travels in his motorhome.  He
can't wait to get back down south where he now lives in his mind
and which is fast becoming his centre of vital interest and
"closer connection."
His Canadian friends have died, divorced, moved away, are still
working or go south to  different places to spend their winters.
His closer connection,  "his home" without much doubt, is now in
the U.S.
The following is an article I wrote for Joe Martin's Vancouver
Business Newspaper in November, 1989. (note that rates/amounts
have been changed)
Canadians with property and investments in the U.S. are looking
at a big surprise when they sell out or when they die.
The U.S. government is looking for their pound of flesh and they
are getting it.
A Non-Resident and Non-Citizen of the U.S. who owns property in
the U.S. can be in for a RUDE AWAKENING when they sell it or die.
For instance (ignore exchange please), if you sell a place in
Palm Springs and made $100,000, that $100,000 profit might have
been  your tax free $100,000 exemption in Canada. But - the U.S.
will tax the full $100,000 anyway so there might not be any sense
in claiming it tax free in Canada if you have another item you
could have used on your T664 Canadian exemption election form.
(Report the profit and claim a foreign tax credit on your
Canadian Return)
If you die, the situation becomes even worse with the possibility
of a capital gains tax and an estate tax.
A form 706NA must be filed and if, for example, The taxable US
estate is valued at $100,000 there would be $8,200 to pay (18% of
first $10,000, 20% of next $10,000, plus 22% of next $20,000
[$100,000 - $60,000]) of Federal Tax. As well there might be a
State Tax (different for each state) which can usually be used as
a partial deduction against the federal tax.
The new treaty took effect as of Nov 11, 1988 and will also allow
the U.S. estate tax to be credited to Canadian Capital gains tax.
The new rules work like this.  Everyone now gets a $625,000
(proposed to go higher) exemption for U.S. estate taxes.  If you
are a non-resident and non-citizen of the U.S., this exemption is
modified in the following manner:
I know that the exemption is going to $675,000 and maybe a
million, I have used an old calculation here. The total WORLDWIDE
assets must be counted.  Let's assume that the total is
$1,500,000.  If the U.S. part of these assets was a $300,000 U.S.
condominium in Palm Springs, the estate exemption would be:
        $1,500,000 x's $625,000 = $125,000
Estate tax would be payable on $175,000 U.S. ($300,000 -
Gift tax rates (form 709) and estate tax rates (forms 706 or
706NA) are the same once the exemption is passed.
The reason that the rates are the same is that any gifts made up
to 3 years before death are added back into the estate.
Gift tax is dangerous. Remember that the "payer," not the
recipient (unless the recipient is not available or broke after
giving everything away), pays the gift tax. The exemption for
everybody is $10,000.  If you have a spouse who is a resident or
a citizen of the U.S., you may give any amount to your spouse.
However!, if your spouse is a non-resident of the U.S., that gift
is limited to $100,000 U.S.
Therefore, if you are a Canadian and you decide to give the
$100,000 summer home in Bemidji, MN, or your Palm Springs, CA,
condo, or your Cape Coral, FL,  condo to your 4 children, if you
do not do it in "$10,000 each per year" stages, you will have
significant gift tax to pay.  The same thing can happen when you
put your "new" non-resident spouse's name on the Palm Springs
condo when the value is over $200,000 or when you put your
children's names on your bank account in Canada if you happen to
be a U.S. citizen living in Canada.  The following rates of gift
and estate tax apply:
Column A        Column B        Column C        Column D
                                                Rates of Tax
Taxable         Taxable         Tax on          on excess Amount
amount          amount in       over amount
--              10,000          ----            18%
10,000          20,000          1,800           20%
20,000          40,000          3,800           22%
40,000          60,000          8,200           20%
60,000          80,000          13,000          26%
80,000          100,000         18,200          28%
100,000         150,000         23,800          30%
150,000         250,000         38,800          32%
250,000         500,000         70,800          34%
500,000         750,000         155,800         37%
750,000         1,000,000       248,300         39%
1,000,000       1,250,000       345,800         41%
1,250,000       1,500,000       448,300         43%
1,500,000       2,000,000       555,800         45%
2,000,000       2,500,000       780,800         49%
2,500,000       3,000,000       1,025,800       53%
3,000,000       10,000,000      1,290,800       55%
10,000,000      21,040,000      5,140,800       60%
21,040,000      ----            11,764,800      55%
If this sounds like I am only talking about having a house in
Palm Springs, Cape Coral, or Phoenix, be assured, it doesn't stop
there. It also applies to shareholdings of U.S. companies. If you
own U.S. securities or stock (which have to go through a U.S.
transfer agent to be sold or transferred), you are also in
trouble. The same rules and rates apply even if you have never
been to the U.S. and the stock is in a safety deposit box in
Regina, or your broker is holding it for you in St John's,
If your only U.S. asset is less than $1,250,000 U.S. stock there
is a special exemption in the new treaty. There would not be any
U.S. estate tax in this case.  However, if you owned $100,000
worth of U.S. stock located in Canada and a $100,000 condominium
in the U.S., you would have to file a 706NA estate tax return
plus a state return if the property was in a state with an estate
Right now, we are having trouble getting stocks released from two
transfer agents in the U.S. because they want an estate tax
clearance from the IRS.
If that isn't confusing enough so far, on the other hand, "money
on deposit in a U.S. bank or Savings and Loan or Insurance
Company does not count for U.S. estate tax if it is `not
effectively connected with conducting a trade or business within
the U.S." This means that if you died leaving a $1,460,000
deposit in the Bank of America, there would be no tax on the
interest or any estate tax on the capital. But if you died owning
$1,460,000 worth of shares of the Bank of America and the shares
were in your wall safe at home in Horseshoe Bay, Saskatoon,
Halifax, or Sudbury, you would owe tax on the dividends (to the
U.S. and Canada) and estate tax to the Federal U.S. government
(no state tax as it is not situated in a state).
What is the reason for this? Back in the oil problem days, the
U.S. Congress had to recognize that if they taxed
non-resident/non-citizen bank deposits, tens of billions of
dollars would be pulled out of Chase Manhattan, CitiBank, Bank of
America and so on. To keep that money there and stop their
banking system from collapsing, they passed legislation which
exempted foreign owned bank accounts from U.S. tax if they were
deposit accounts only and not effectively connected with
conducting a business within the U.S. The only requirement was
that the holder have a U.S. `taxpayer identifying number' and
report to the bank/savings and loan that he/she is still a
non-resident/non-citizen at least once every three years. If the
situation changes he/she is to notify the institution within
thirty days.
Money on deposit in the U.S. is not subject to U.S. income tax or
estate tax provided it is not effectively connected with a U.S.
Trade or Business (remember, the interest IS subject to Canadian
Tax so report it on your Canadian return). If the money is on
deposit to fund your rental house in the states, the interest IS
taxable on your U.S. federal income tax return because a rental
house is generally considered to be effectively connected with a
U.S. business.  This is an automatic election which you make when
you file your 1040NR and claim expenses against the rent.  If the
rental house was not effectively connected with a U.S. business,
the U.S. federal income tax would be a 30% of the GROSS rents
with no expenses allowed.
As you can see from the article, there can be "taxing" moments
between the two countries.
So what are the rules?
Well, to leave Canada for tax purposes, you must give up clubs,
bank accounts, memberships, driving licences, provincial health
care plans, family allowance payments (if you are a returning
resident, you can continue to get Family Allowance out of the
country), your car, and furniture. You can keep a house here as
an investment and rent it out, but it must be rented on lease
terms of a year or more. And you MUST have an agent sign an NR6
for you (see example). This NR6 has the Canadian Resident AGENT
** guarantee the Canadian Government that if YOU do not pay your
tax to Canada, the AGENT WILL. Even after fulfilling the
foregoing, the Canadian government can still tax you or "try" to
tax you on your income out of the country. If you are being paid
by a Canadian Company, they can quite often succeed.
Even though you can collect family allowance out of the country,
don't! One client's wife found out that she could get family
allowance out of the country if she said they were coming back to
Canada. She got some $3,000 of family allowance and cost the
family some $80,000 in income tax when they came back to Canada
from Brazil. I will never forget the husband's expression when he
found out why he had been reassessed and I will never forget his
wife's explanation. She said he was a skinflint and never gave
her any money. The total episode cost them their house.
** The "agent" referred to above can be a friend, relative, or a
business such as ours. We charge a minimum of $40.00 per month to
be an "AGENT" for an NR-6 filing. This $480 per year is "in
addition" to any other fees but "well worth it" of course. It
stops your mother, father, brother, next door neighbour or
ex-best-friend from being plagued by paperwork they do not
It is possible to be physically "in Canada" and be treated as a
Non-Resident and it is possible to be out of the country for
seven years, or never have even lived in Canada, but wanted to,
and be taxed as a Canadian resident as the following three cases
show. In case you missed it, the reason for the different rulings
is the "INTENT" of the parties involved.  Wolf Bergelt intended
to leave Canada.  David MacLean was only working out of the
country.  He still maintained a residence and could not ever
become a resident of Saudi Arabia anyway. Dennis Lee "wanted" to
live in Canada.
In 1986, Wolf Bergelt won non-resident status before Judge
Collier of the Federal Court, even though he was only out of the
country for four months and his family stayed behind to sell his
house. He had given up his memberships, kept only one bank
account and rented an apartment in California until his house in
Canada was sold. Four months after his move, his company advised
him that he was being transferred back to Canada. Judge Collier
said his move was a permanent (although short) move and he was a
non-resident for tax purposes for those four months.
In 1985, David MacLean lost his claim for non-residence status
even though he was gone for seven years. He kept a house and
investments in Canada and returned a couple of times a year to
visit parents. He had even been to the Tax Office and received a
letter on January 29, 1980 stating that his Canadian Employer
could waive tax deductions because he was a non-resident.
However, he did not advise his banks, etc. that he was a
non-resident so that they would withhold tax, he did not rent his
house out on a long term lease and he did not do any of the
things that makes a person a "NON-RESIDENT". Judge Brule of the
Tax court of Canada said that he thought Mr. MacLean had stumbled
on the non-resident status by chance rather than by design. In
other words, to become a non-resident of Canada, you must become
a bone fide resident of another country.  As a rule, only a
Muslim born in Saudi Arabia to Saudi Arabian parents can become a
Saudi Arabian citizen.  The best that David MacLean can hope for
is that he has a Saudi Arabian temporary work permit.
In other words, when a person leaves a place, they usually leave
and establish a new identity where they are because the "new
place" is where they live now. Trying to "look" like a
non-resident is not the same as "BEING" a non-resident - think
about it.
In 1989, Denis Lee won part but lost most of his claim for
non-resident status. He was a British Subject who worked on
offshore oil rigs. He maintained a room at his parents house in
England and held a mortgage on his ex-wife's house in England.
For the years 1981, 82 and 83 he did not pay income tax anywhere.
in 1981 he married a Canadian and she bought a house in Canada in
June of 1981. On September 13, 1981, he guaranteed her mortgage
at the bank and swore an affidavit that he was "not" a
non-resident of Canada. [As I have said in the capital gains
section of this book, bank documents will get you every time.]
During this time he had a Royal Bank account in Canada and the
Caribbean but no Canadian driver's licences or club memberships,
Judge Teskey said:
"The question of residency is one of fact and depends on the
specific facts of each case. The following is a list of some of
the indicia relevant in determining whether an individual is
resident in Canada for Canadian income tax purposes. It should be
noted that no one of any group of two or three items will in
themselves establish that the individual is resident in Canada.
However, a number of the following factors considered together
could establish that the individual is a resident of Canada for
Canadian income tax purposes":
- past and present habits of life;
- regularity and length of visits in the jurisdiction asserting
- ties within the jurisdiction;
- ties elsewhere;
- permanence or otherwise of purposes of stay;
- ownership of a dwelling in Canada or rental of a dwelling on a
long-term basis (for example, a lease of one or more years);
- residence of spouse, children and other dependent family
members in a dwelling maintained by the individual in Canada;
- memberships with Canadian churches, or synagogues, recreational
and social clubs, unions and professional organizations (left out
- registration and maintenance of automobiles, boats and
airplanes in Canada;
- holding credit cards issued by Canadian financial institutions
and other commercial entities including stores, car rental
agencies, etc.;
- local newspaper subscriptions sent to a Canadian address;
- rental of Canadian safety deposit box or post office box;
- subscriptions for life or general insurance including health
insurance through a Canadian insurance company;
- mailing address in Canada;
- telephone listing in Canada;
- stationery including business cards showing a Canadian address;
- magazine and other periodical subscriptions sent to a Canadian
- Canadian bank accounts other than a non-resident account;
- active securities accounts with Canadian brokers;
- Canadian drivers licence;
- membership in a Canadian pension plan;
- holding directorships of Canadian corporations;
- membership in Canadian partnerships;
- frequent visits to Canada for social or business purposes;
- burial plot in Canada;
- legal documentation indicating Canadian residence;
- filing a Canadian income tax return as a Canadian resident;
- ownership of a Canadian vacation property;
- active involvement with business activities in Canada;
- employment in Canada;
- maintenance or storage in Canada of personal belongings
including clothing, furniture, family pets, etc.;
- obtaining landed immigrant status or appropriate work permits
in Canada;
- severing substantially all ties with former country of
"The Appellant claims that he did not want to be a resident of
Canada during the years in question. Intention or free choice is
an essential element in domicile, but is  entirely absent in
Even though Dennis Lee was denied residency by immigration until
1985 (his passport was stamped and limited the number of days he
could stay in the country) and he did not purchase a car until
1984, or get a drivers licence until 1985, Judge Teskey ruled
that he was a non-resident until September 13, 1981 (the day he
guaranteed the mortgage and signed the bank guarantee) and a
resident thereafter.
My point is made. Residency for "TAX PURPOSES" has nothing to do
with legal presence in the country claiming the tax. It is a
question of fact. My thanks to Judge Teskey for an excellent
list. The italics are mine and refer to the items which I usually
see people trying to "hold on to" after they leave and are trying
to become non-residents. No single item will make you a resident,
but there is a point where the preponderance of "numbers" leap
out and say, "He / She is a resident of Canada, no matter what he
/ she says."
The case above is not unusual in any way. It is a fairly typical
situation in my office.
In 1990, John Hale was taxed as a resident on $25,000 of
directors fees he had received from his Canadian Employer and on
$125,000 he received for exercising a share stock option given to
him when he had been a resident of Canada (the option, not the
stock). Judge Rouleau of the Federal Court ruled that section
15(1) of the Great Britain / Canada Tax Convention did not
protect the $125,000 as it was not "salaries, wages, and other
remuneration". It was, however a benefit received by virtue of
employment within the meaning of section 7(1)(b) of the act.
Even a car you do not own can make you a resident as the next
sailor found out.
In 1988, Frederick Reed was claimed by the Canadian Government as
one of their own. He lived on board ship and shared an apartment
with a friend in Bermuda but only occasionally. He also stayed
with his parents in Canada when visiting his employer in Halifax.
Judge Bonner of the Tax court ruled that he could not claim his
place of employ or the ship as his residence and just because he
did not have a fixed abode, did not make him a non-resident. He
was also the beneficial owner of a car in Canada which even
though of minor consequence, served to add to his Canadian
Residency. He had in fact borrowed money from a credit union to
buy the car, even though it was registered in his father's name.
He had maintained his Canadian Driver's licence as well.
An interesting case in June, 1989 involved Deborah and James
Provias who left Canada in October of 1984. They had sold a
multiple unit building to James' father on September 21, 1984 but
the statement of adjustments did not take place until December 1,
1984. They tried to write off rental losses and a terminal loss
against other income as `departing Canadians'. Judge Christie of
the Tax Court ruled that they had left before the sale and were
not entitled to the terminal loss or another capital loss as
these could only be applied against income earned in Canada from
October 13, 1984 (the day they left) to November 30, 1984 (the
day before the sale) and there was no income, only a rental loss.
But June, 1989 was a good month for Henry Hewitt. He had been a
non-resident living in Libya for four years and received some
back pay after returning to Canada. DNR tried to tax him on the
money but Judge Mogan of the Tax Court came to the rescue. He
ruled that although Canadians were usually taxable on money when
received, that assumed that the money itself was taxable in
Canada, which was not true in this case.
In 1989, James Ferguson lost his claim for non-residency status
but from the information, it didn't stand a chance anyway. He had
been in Saudi Arabia on a series of one year contracts for four
years. His wife remained employed in Canada, and he kept his
house, car, driver's licence, union membership, and master
plumber's licence. Judge Sarchuk ruled that he had always
intended to return to Canada and was a resident.
A similar situation involved John and Johnnie M. Eubanks in the
United States. He was working on an offshore oil rig in Nigeria
with a Nigerian work permit and attempted to claim non-resident
status for the purposes of exempting the foreign earned income
exclusion. His wife was in the United States at all times and
because he worked 28 days on and 28 days off, he returned to the
U.S. for his rest periods using 4 days for travel and 24 days for
rest with his family. He did not spend any 330 day period (out of
a year) in Nigeria and only had a residency permit for the
purposes of working in Nigeria. Judge Scott ruled he was a
resident of the U.S. and taxed him some $20,000 with another
$6,000 penalties and interest.
The Tax departments in Canada and the U.S. issue Interpretation
Bulletins and Information Circulars and Guidance Pamphlets. These
documents sometimes get people in trouble because the individual
reads the good part and doesn't pay any attention to the
exceptions. The following case ran contrary to a Guidance
Pamphlet issued by the IRS.
On and Off-shore Oil rigs were involved with William and Margaret
Mount and Jesse and Mary Wells. William and Jesse worked in the
United Arab Emirates. However, they kept their homes and families
in Louisiana and kept their driver's licences in Louisiana and
voted in Louisiana. No evidence was shown that they had tried to
settle in The United Arab Emirates. Judge Jacobs turned down
claimed exclusions of approximately $75,000 each.
There isn't any question about what oil rig people talk about on
oil rigs. It has to be "how to beat the tax man". Unfortunately,
they all seem to think it is easy. Another such story follows.
In 1989, Clarence Ritchie found out that bona fide residence
means just what it says. You cannot be a non-resident of the U.S.
for tax purposes if you are not a bona fide resident of another
country. He was working on the Mobil Oil Pipeline in Saudi Arabia
and although when he left he was married with a couple of kids,
by the time he returned permanently, he was a happily divorced
man. Judge Scott ruled that though he did not have an abode in
the United States, he had not established one in Saudi Arabia and
therefore was not entitled to the foreign earned income exclusion
which requires you to be away for 330 days out of 365. He had
worked a 42 days on, 21 days off schedule and usually returned to
the U.S. for his days off although he did spend time in Tunisia,
England, Italy and Greece.
On a final note, as explained on page 143 of the "PINK" 17th
edition of my ULTIMATE TAX BOOK, it is possible to have three
countries after you for tax. If you are thinking of taking a job
because a recruiter told you the money is tax free, think twice
and check three times with competent individuals about what the
rules "really are". No government likes giving up the right to
tax its citizens.
Non-residents of Canada with investments in Canada are subject to
a 25% non-resident withholding tax on any money paid to them
while they are out of the Canada. Therefore, if they have $10,000
in the Bank of Montreal and they live in Argentina, The Bank of
Montreal must withhold 25 cents out of every dollar of interest
paid to the account. Most tax treaty countries such as Great
Britain, Germany, the United States, and Australia have a
reciprocal agreement with Canada that limits the withholding to
15%. So we have the anomaly that a Canadian with money in a bank
in the U.S. has no withholding but an American with money in a
Canadian Bank has 15 cents out of every dollar withheld as a
foreign withholding tax. The American would report his interest
on schedule A of his 1040 tax return and claim the tax withheld
as a foreign tax credit on a form 1116.
More important perhaps is the problem with rental properties in
Canada. When owned by a non-resident, they are subject to a 25%
withholding (or 15% if living in Bangladesh) tax. If the renter
does not pay this tax,  the government can come along two years
later and demand the tax.
Imagine the consternation of a tenant of a house in the British
Properties in West Vancouver, or Rosedale in Toronto. Assume the
tenant has been paying $2,000 a month for a $500,000 house owned
by a Hong Kong resident. After three years of paying $24,000 a
year to the `non-resident', they finally buy a house and move.
Two months later, there is a knock on the door and a National
Revenue representative is standing there demanding 25% of $72,000
for NON-RESIDENT withholding tax (this is a true story by the
way, only the owner was in London).
There is a way around this problem. The tenant can ask to see, or
rather DEMAND to see a copy of the landlord's filed and accepted
NR6 form. (See forms in back of book). This form allows the
tenant or agent of the landlord to deduct a lesser amount (or nil
if a loss) than 25% of the gross rent. It allows for expenses to
be taken off and the tax can then be withheld at 25% of the net,
rather than the gross. The property management division of david
ingram & Associates Realty Inc. files about 300 of these NR6
forms a year. (This is only necessary if you are paying directly
to a landlord whom you KNOW to be a non-resident of Canada.  If
you are paying to an agent or Canadian Resident, you are okay.)
Please note, the NR6 MUST BE FILED BEFORE the first rent cheque
is received or 25% of the gross rent must be remitted. For years,
we were in the habit of filing `this years' NR6 late with last
years tax return. In 1989, National Revenue stopped accepting
this sloppy practice and demanded them on time.
If paying 25% of the GROSS rent to Canada sounds bad, cheer up.
The United States taxes the Canadian 30% in the same situation.
To avoid this, the Canadian needs to notify the U.S. Government
that he wishes to be taxed as a business rental house on the "net
income" received. But if you do not notify the IRS in advance,
the IRS CAN tax you at the 30% of gross rate.
The situation is different with the sale of REAL ESTATE. A
non-resident with property in Canada who sells the property is
subject to a withholding tax of 33 1/3% on the GROSS sale price
unless they fill out a form 2062A (sample at back of book) and
submit it to Revenue Canada for approval. You cannot use the form
in the book, it is the wrong size. It must be obtained from
Revenue Canada and filled out in quintuplet (5 copies). It does
not have to be filed before the sale unless you need the money
immediately to close a back to back deal - the lawyer can keep
money in his trust account until the form is approved.
CAUTION - This is serious, a Realtor and lawyer who were not
aware of this fact are at possible risk of law suit from a
purchaser. The purchaser was called upon to pay 25% of the
purchase price of the property to Revenue Canada for failure to
withhold. The rate was 25% up to 1987, 30% for 1988 and 1989, and
is now 33 1/3%). There is a proposal to make it 50% unless the
form 2062 is filed. The situation is serious enough that one
should not accept a person's declaration that they are a resident
as sufficient reason to "not withhold tax". In one case, the
purchaser and the real estate agent drove the vendor to the
airport to fly back to Hong Kong. The vendor is not a resident of
Canada. Is it any wonder that National Revenue wants to collect
the tax from the purchaser and the purchaser wants to sue the
real estate agent and lawyer. "THE ONLY SAFETY IN THIS SITUATION
What form T2062 does is allows you to calculate the actual gain
WHICH WILL BE EARNED AND TAXABLE. The purchaser may then only
DEDUCT/pay a withholding tax on the taxable gain, not the gross
sale price. Revenue Canada is wonderful when it comes to quick
approval of this form. I would love to give out names of people
who have gone overboard to accommodate clients but they have
said, "NO, NO, NO! " (Please note. Even though Real Estate
Commissions and other costs of sale are deductible when
calculating the actual taxable income for tax purposes on a
return, they may NOT be deducted for the purposes of the T2062).
If you are having trouble with a sale or purchase with a
non-resident, feel free to call upon the services of our office.
David Ingram at (604) 649-4755 or FAX (604) 649-4759 is available
to assist your lawyer or real estate agent. In addition, if you
need the services of a lawyer for this special service, David
Stoller, LLB shares office premises with us and is available at
the same numbers.
The U.S. government does the same thing when a Canadian is
selling property in the states. They have a 10% withholding tax
on the gross as well and there is usually a state government
withholding of another 3 1/2%. However, all is not lost. The U.S.
government has a form as well. It is form 8288-B and is
reproduced at the back of this book as well, next to the 2062.
You can use this form or a photocopy to request a reduction or
total cancellation of the 10% withholding. For instance, if you
inherited a condo in Wheeling, West Virginia and sold it right
away, the estate tax would be paid already and you would have
inherited it at its present value. There would be no capital
gains expected and therefore, you could get the withholding
In addition, if the property is being transferred for $300,000 or
less and is being used as a personal residence by the purchaser,
and the purchaser will sign a letter saying that they intend to
live it for six months or more a year for the next two years as a
principal residence, they or the escrow agent do not have
liability for withholding tax. However, it is still my opinion
that if on either side of this problem, one should read pages 17
and 18 of the 1990 edition of Publication 17 for more information
and following that format, write to the Internal Revenue Service
with an 8288 and ask for the exemption formally. Remember also
that individual states like California also have a withholding of
(California 3 1/3%) non-resident tax and it is necessary to write
to them as well.
(After all, why should the average person get stuck with
withholding tax in what is an extremely sophisticated tax
REMEMBER THOUGH, Real estate capital gain profits from sales in
the US by Non-residents are subject to ALTERNATIVE MINIMUM TAX.
The rate started at 17% in 1987 and is 26% today in 1999.
That means that if you had bought a property for $10,000 and sold
it now for $110,000 and had $11,000 tax withheld, you will;
actually owe the IRS another $15,000 when you file your tax
return.  When we prepare these returns, about one/half get
refunds, half pay more. See my June, July and August newsletter
for more information.  (Page ???? in this book).
The manual says the preparation of the 8288A and B takes a total
of 4 hours for the first one you do (i.e. record keeping is 1 hr,
33 min; learning the law of the form is l hr, 43 min; preparing
the form is 37 min; and copying, mailing, etc. is another 20
min). It is mailed to:
The Director
Philadelphia Service Center
P. O. Box 21086
Philadelphia, PA 19114
Again, if you are having trouble or cannot find anyone locally to
help, call our office at (604) 649-4755.
All American citizens must file American tax returns for as long
as they remain citizens of the U.S.A. This means that even if you
are a landed immigrant in Canada and intend to take out
citizenship, you must continue to file American returns. This may
seem a needless task, but if you don't do this and you suddenly
decide to take a trip out of the country, you may have problems
obtaining a passport. The only place you can get a passport is
from the American Embassy or Consulate and they want to know if
you have filled out your American returns. If not, they could
refuse to issue your passport. I have seen several exotic trips
ruined because of this.
Because of exemptions and foreign tax credits there is usually no
(or very little) additional tax to pay, but you must still file
an American return. Since the first edition of this book, it has
become obvious that if there is a lot of interest, royalties,
dividends, rents, or business income, the Alternative Minimum Tax
will kick in and only allow 90% of the foreign tax credit when
the incomes exceed $45,000 for a joint return, $33,750 for a
single person, and $22,250 for a married person filing
separately. If the income is only earnings and less than $70,000
and the rest of the income is under the stated amounts above
there should be no U.S. tax.
Let's assume you are a retired U.S. citizen living in Canada with
an income of $10,000 U.S. Social security and $10,000 in interest
from the United States. You have Canadian interest of $10,000 and
a Canadian Pension of $15,000 from University of Toronto and
$7,000 from Canada Pension Plan and Old Age Security. Oh yes, you
get  $3,000 of interest from England for a total of $55,000 of
which $50,000 is taxable income (this is a true story by the
Where do you pay your tax? (all money in Canadian Funds)
Great Britain will take $450.00 at source (15%).
You will prepare your U.S. return reporting your U.S. Social
Security ($5,000 of it will likely be taxable because of your
total income [85% is taxable over about $25,000]), your U.S.
interest, your Canadian interest, the British estate, and your
Canadian pensions. Calculate your tax. Then `prorate' the tax
among the income from the different countries. i.e. if your total
tax was $10,000, then the Great Britain portion would be $3,000 /
50,000 x $10,000 = $600. The Canadian Portion would be $32,000 /
50,000 x $10,000 = $6,400 and the American portion would be
15,000 / 50,000 x $10,000 = $3,000. (This is not perfect - the
real calculation is done on form 1116 and has prorated
exemptions, etc. calculated in but you get the idea I hope. You
will prepare your Canadian return reporting exactly the same
amounts except that you will report the whole $10,000 Social
Security and claiming $1,500 as a 15% deduction on line 256. If
your tax was the same $10,000 in Canada, then the percentages
would be the same (for the example only).
Now you do not want to pay $10,000 to Canada plus $10,000 to the
States plus the $450 to Great Britain. That would be double and
even triple taxation on the Great Britain money.
What you do is file the U.S. return reporting all the money and
calculating the tax owing of $10,000. You would then fill out an
1116 Foreign Tax Credit form and claim credit for the $450 paid
to Great Britain. This would give you a credit of $450 against
your $10,000 tax and you would now owe $9,550 to the U.S. You
would then do another Form 1116 (maybe one each for pensions and
interest) for the Canadian Income. In this example, that would
result in a credit for $6,400 for the tax paid to Canada and you
would now owe ($9,550 - $6,400) $3,150 to the U.S. government.
In Canada, you would do the same calculations and get about the
same result. The one place that you would pay double taxation (or
triple) would be that you are paying an extra $150 to BOTH the
U.S. and Canada on the British Estate Income. If we find these
situations we recommend efforts be made to transfer the corpus of
the estate to one of the taxing countries. On the U.S. return, we
cannot claim credit for the extra $150 to Canada because the
Estate did not come from Canada, and on the Canadian Return, we
cannot claim credit for the $150 extra paid to the U.S. because
the money did not come from the States.
If you do not want to attempt these rather involved calculations,
mail the paperwork to me at:
108 "the Gallery"
100 Park Royal South,
West Vancouver, BC, V7T 1A2
Today, for instance, tax work arrived from Athens, Greece,
Auckland, New Zealand, Hong Kong, Honolulu, and Brussels.
This was a 1990 analysis of the situation of a Very High Profile
couple who desired to live and work in the United States and
Canada. Unfortunately, it does not matter any more.  They were
divorced, he remarried, and he has since died of cancer.
604 980-0321 - FAX 604 980-0325
taxman at
December 11, 1990
My Understanding:
I understand that your husband is a U.S. Citizen with landed
immigrant status in Canada and that you are a Canadian Citizen
with a U.S. Green Card.
I also understand that the desire of both is to continue having
the benefit of both worlds, i.e. the ability to move back and
forth across the International Border and work in either place
with no fuss.
While the following is not written in stone, the general tone is
what would usually be followed:
Re: Wife
Although leaving Canada and obtaining a U.S. "Green Card" usually
stops the taxation of World Income by Canada, it will not stop
Canadian Taxation, if close ties are maintained with Canada
either through family, marriage, investments in Canada, or the
providing of services in Canada. Page 183 of my 1990 Income Tax
Book points out how the countries arrange taxation between them.
The convention implies that only one country will tax. Nothing is
further from reality. What usually happens in the case of a
person who is maintaining close ties with both countries (legally
or not), is that BOTH countries will tax and honor foreign taxes
paid to the other country on income which was sourced in that
other country. The U.S. allows the credits on a form 1116, Canada
allows the credits on a Schedule 1.
The previous paragraph was written with the understanding that
the general application of taxation by Canada is that if a person
leaves the country, they are no longer taxable to Canada on their
world income. This premise is different from that of the U.S. and
of course your husband is caught in that web and the old Charlie
Chaplin rule (see end of section)
Your husband is a U.S. Citizen which means he is taxable on his
world income anywhere he goes with some exemptions. If he
establishes a bona fide residence in another country (i.e.
Canada), he may exempt up to $70,000 of employment type income
from U.S. Income Tax. This is a pro-rated figure, so that if he
was physically in the U.S. for 180 days, only 185/365 x $70,000
would be exempt or an amount of $35,479.45.
Because he has landed immigrant status in Canada, the husband is
also taxable on his world wide income by Canada. Because the
Canadian Income Tax Rate is higher, if the source of funds is
Canada, usually there is no tax to pay to the U.S. because the
foreign tax credits on Form 1116 will usually take care of them.
The exception is for Capital Gains. We only tax 75% of capital
gains and the first $100,000 is tax free. Therefore, without
proper planning, a U.S. citizen can find himself paying double
taxation by claiming the exemption in Canada, paying tax to the
states without a credit, and then when the exemption has run out
in Canada, paying tax to Canada in other years.
This is a delicate matter. It is very easy for either party to
lose their status in the other country by their actions.
For instance, one famous actor we all know lost his landed status
in Canada when he was away for two years without notifying the
Immigration Department and getting permission to be away as a
returning resident.
Because of this fact, it is important that the parties understand
that establishing a bona fide residence in Canada could cause the
wife to lose her status in the U.S., and going for citizenship
for the wife in the U.S. could cause the husband to lose his
status in Canada.
i.e. It is a conundrum. How does the husband say to Canada, Hi,
here I am, full time to become a citizen, while the wife is
saying the same thing in the U.S. I suggest that for U.S.
purposes, the husband not worry about Bona Fide Residence in
It does not need to be a problem though. It seems to me that you
have the best of both worlds as it is. By moving back and forth
on a fairly regular basis and by properly preparing tax returns
in both countries and claiming foreign tax credits, you can have
your cake and eat it too.
Yours truly
the CEN-TA Group
david ingram
British Columbia Income Tax, Real Estate & Immigration
P.S. The Charlie Chaplin Rule is:  The United States will
continue to tax income, estates and gifts associated with U.S.
citizens for ten years after they give up their citizenship
unless they can prove that they did not give up their citizenship
for tax reasons (what other reason could there be).
Answers to this and other similar  questions can be obtained free
on Air every Sunday morning.
Every Sunday at 9:00 AM on 600AM in Vancouver, I, david ingram am
a permanent guest on Fred Snyder of Dundee Wealth Managers' LIVE
talk show called "ITS YOUR MONEY"
Those outside of the Lower Mainland will be able to listen on the
internet at
Call (604) 280-0600 to have your question answered.  BC listeners
can also call 1-866-778-0600.
Callers to the show and questioners on this board can also attend
the Thursday Night seminars on finance and making your Canadian
Mortgage Interest deductible.
David Ingram's US/Canada Services
US / Canada / Mexico tax, Immigration and working Visa
US / Canada Real Estate Specialists
4466 Prospect Road
North Vancouver,  BC, CANADA, V7N 3L7
Res (604) 980-3578 Cell (604) 657-8451
(604) 980-0321
New email to davidingram at
Disclaimer:  This question has been answered without detailed
information or consultation and is to be regarded only as general
comment.   Nothing in this message is or should be construed as
advice in any particular circumstances. No contract exists
between the reader and the author and any and all non-contractual
duties are expressly denied. All readers should obtain formal
advice from a competent and appropriately qualified legal
practitioner or tax specialist in connection with personal or
business affairs such as at If you forward this
message, this disclaimer must be included."
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Sacramento, Taos, Grand Canyon, Reno, Las Vegas, Phoenix, Sun
City, Tulsa,
Monteray, Carmel, Morgantown, Bemidji, Sandpointe, Pocatello,
Custer, Grand Forks, Lead, Rapid City, Mitchell, Kansas City,
Houston, Albany, Framingham, Cambridge, London, Paris, Prince
George, Prince
Rupert, Whitehorse, Anchorage, Fairbanks, Frankfurt, The Hague,
Madrid, Atlanta, Myrtle Beach, Key West, Cape Coral, Fort Meyers,
Warsaw, Auckland, Wellington, Honolulu, Maui, Kuwait, Molokai,
Shanghai, Tokyo, Manilla, Kent, Winnipeg, Saskatoon, Regina, Red
Deer, Olds,
Medicine Hat, Lethbridge, Moose Jaw, Brandon, Portage La Prairie,
Craik, Edmonton, Calgary, Victoria, Vancouver, Burnaby, Surrey,
Dublin, Belfast, Glasgow, Copenhagen, Oslo, Munich, Sydney,
Brisbane, Melbourne, Darwin, Perth, Athens, Rome, Berne, Zurich,
Nanking, Rio De Janeiro, Brasilia, Colombo, Buenos Aries,
Churchill, Lima, Santiago, Abbotsford, Cologne, Yorkshire, Hope,
Kelowna, Vernon, Fort MacLeod, Deer Lodge, Springfield, St Louis,
Bradford, Stratford on Avon, Niagara Falls, Atlin, Fort Nelson,
Fort St
James, Red Deer, Drumheller, Fortune, Red Bank, Marystown, Cape
Truro, Charlottetown, Summerside, Niagara Falls, Albany
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