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George and Gina Anderson, (Canadian citizens), moved to Europe on August 15th, 2020 to open and incorporate a café in a small Italian village. Prior to moving, George earned $65,000 in 2020 as a computer programmer and Gina earned $67,000 in 2020 as a registered nurse. (The couple did not have any other income besides their salaries prior to moving.)
They are both in their 60s and plan to retire in Italy, which is Gina's birthplace. They sold their home prior to moving to Europe. As the couple only expects to return to Canada every second year, they cancelled their bank accounts and driving licenses. Their café was successful in 2020 and earned a pre-tax profit of $25,000 by year's end.
Required:
Determine the residency status of George and Gina and their café for Canadian tax purposes in 2020 and discuss the Canadian tax treatment, if any, of their personal and business income. (Assume there were no assets with realizable gains upon their move.)
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