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posted Oct 13, 2023 4:20:04 PM

Taxation on Restricted Stock Units granted before moving to Canada

I moved from US to Canada in Nov 2021. Had some Restricted stock units granted in 2020 and 2021 that got vested during 2022.  My employer has issue me a T4 (under Box 14) including the full FMV as on vesting date, W-2 (for US) was also issued.

W.r.t the taxation of the RSU's income that are granted in 2020/2021 but vested in 2021, how are these to be taxed from Canada perspective

 

1. Would the entire amount be taxed in Canada (since its on T4) and a foreign Tax credit be taken for the US taxes.

2. Would the RSU amount be split into 2 portions   based on no. of work days in Canada divided by total holding period [grant to vest date] and be taxed only for the Canada specific percentage

*this is per the Hybrid Methodology for Sourcing specified in
20 January 2021 Internal T.I. [phone number removed]I7 - Cross-border Restricted Share Units | Tax Interpretations

Looking for your kind suggestions

 

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Moderator
Oct 16, 2023 6:13:40 AM

We would suggest that you contact the Canada Revenue Agency so that they can direct you.

 

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