Your same-owner share move is not automatically a taxable sale, but Canadian departure tax or a legal-title transfer of qualifying U.S. ESPP shares can create a separate tax event.

248(1), definition of disposition, paragraph (e)

any transfer of the property as a consequence of which there is no change in the beneficial ownership of the property

(c)(1)

the term "disposition" includes a sale, exchange, gift, or a transfer of legal title

Employee Stock Purchase Plan

You satisfy the holding period requirement if you don’t sell the stock until the end of the later of the 1-year period after the stock was transferred to you or the 2-year period after the option was granted.

Employee Stock Purchase Plan

If, at the time the option was granted, the option price per share was less than 100% (but not less than 85%) of the FMV of the share, and you dispose of the share after meeting the holding period requirement, or you die while owning the share, you must include in your income as compensation the lesser of:

Deemed dispositions

If you ceased to be a resident of Canada in the year, you were deemed to have disposed of certain types of property at their fair market value (FMV) when you left Canada and to have immediately reacquired them for the same amount.

Property excluded from deemed disposition

property you owned when you last became a resident of Canada (or property you inherited afterward) if you were an individual who was a resident of Canada for **60 months or less** during the 10-year period before you emigrated and you are not a trust

Form T1161

Even if you do **not** have to file a return, you **must** send Form T1161 on or before your filing due date.

Article XIII(7)

Where at any time an individual is treated for the purposes of taxation by a Contracting State as having alienated a property and is taxed in that State by reason thereof, the individual may elect to be treated for the purposes of taxation in the other Contracting State, in the year that includes that time and all subsequent years, as if the individual had, immediately before that time, sold and repurchased the property for an amount equal to its fair market value at that time.

4.02

The individual takes an adjusted basis in such property for U.S. federal income tax purposes equal to the fair market value of the property as of the date of the deemed disposition under Canada’s deemed disposition rules.

4.02(3)

The individual must make the election by reporting the deemed disposition on the individual’s timely filed U.S. federal income tax return for the individual’s first taxable year ending after the individual’s change of residence and by attaching a Form 8833 to such return.

4.02

If an individual is deemed under Canadian law to have disposed of multiple properties immediately before ceasing to be a resident of Canada with respect to which gain or loss is recognized for Canadian tax purposes in the year of the deemed disposition, the individual may not make an election pursuant to new Article XIII(7) unless the deemed disposition of all such properties results in a net gain for Canadian tax purposes.

Employment income

If you received Canadian-source employment income (including tips, gratuities, and security option benefits) in 2025 for employment duties that you performed in Canada in 2025 or earlier, report it on line 10100 of your income tax and benefit return for the province or territory where you earned the income.

Reporting your income

You have to report your world income (in Canadian dollars) for the part of the year that you were considered a **resident of Canada**.

Resident aliens

If you are a resident alien, you must report all interest, dividends, wages, or other compensation for services, income from rental property or royalties, and other types of income on your U.S. tax return. You must report these amounts whether from sources within or outside the United States.

Purpose of Form

Use Form 8949 to report sales and exchanges of capital assets.

Basis reported to the IRS

For compensatory options granted after 2013, the basis information reported to you on Form 1099-B or Form 1099-DA (or substitute statement) won’t reflect any amount you included in income upon grant or exercise of the option. Increase your basis by any amount you included in income upon grant or exercise of the option.

Who must file

the aggregate value of those foreign financial accounts exceeded $10,000 at any time during the calendar year reported.

When to file

The FBAR is an annual report, due April 15 following the calendar year reported. You’re allowed an automatic extension to October 15 if you fail to meet the FBAR annual due date of April 15.

Reporting thresholds

If you are not married, you satisfy the reporting threshold only if the total value of your specified foreign financial assets is more than $50,000 on the last day of the tax year or more than $75,000 at any time during the tax year.

Specified foreign property

Shares of non-resident corporations are specified foreign property and should be reported, regardless of whether the shares are held through a broker.

Part-year residence

Although the Income Tax Act technically requires reporting for the full tax year, the CRA only requires information on specified foreign property for the period you were a resident of Canada.

Currency exchange rates

Use the exchange rate prevailing when you receive, pay, or accrue the item.