An individual, who became a resident of Bermuda in September 2007 in order to take up employment there, returned to Canada in June 2009. How will his employment income earned upon his return to Canada be treated? In the course of a general response, CRA stated:
Where an individual is a resident of Canada for only part of the year, section 114 provides for the tax treatment applicable to that individual. Under this section, an individual who satisfies certain conditions will be taxed in Canada on the individual’s income for the year: for the part of the year during which the individual was a non-resident, the individual's income for the year will be computed under section 115, which renders taxable income earned in Canada by non-residents subject to the Act. In addition, the application of section 114 gives rise to certain particularities in computing income, allowable deductions, personal tax credits and foreign tax relief.