A CRA opinion based on NR73 depends on the facts you provide. It is not a permanent guarantee that future circumstances will have the same result.
What NR73 is for
The CRA describes NR73 as a form for people who have left or plan to leave Canada, temporarily or permanently, and need help determining their tax residence. It is not an immigration application or a substitute for a tax return. Download the current version and read its instructions before preparing a response.
Official reference: CRA: Form NR73 and current instructions
Treat the decision to request an opinion as part of your departure assessment. An article cannot determine whether you should submit it. Discuss any request received from the CRA with your adviser, including the response deadline.
Understand the limits of an opinion
The CRA states that an NR73 opinion relies entirely on the facts supplied. It is not binding on the CRA and may be reviewed later, with supporting documents requested. An advance income tax ruling is a separate process that may be available in appropriate circumstances.
Official reference: CRA: residence status, Income Tax Folio S5-F1-C1
This makes accuracy more useful than a persuasive narrative. Include facts that complicate the position, such as a home still available in Canada or a household moving in stages. If a detail is uncertain, explain what is known and how it will be confirmed.
Assemble your preparation file
- Timeline: actual and planned departure dates, later family moves and visits back to Canada.
- Homes: ownership or rental arrangements, availability for your use and relevant dates.
- Household: where your partner and dependants live and any temporary arrangements.
- Work: where you perform duties, who employs you and business interests you continue to manage.
- Connections: the Canadian and foreign ties that help explain your circumstances.
- Supporting records: an index of documents you have and records still missing.
A short timeline can prevent inconsistent answers across sections. For example, distinguish the date you signed a lease from the date you began living there. Keep draft answers clearly labelled so they cannot be confused with a submitted version.
Review the answers before submission
Read the completed form alongside your other records. Do dates agree with travel history? Does an address represent where you live or only where you receive mail? Are intentions clearly identified as intentions? Ask your adviser to flag assumptions that need evidence.
Follow the current CRA instructions for delivery and attachments. Keep the exact submitted version, submission evidence and any response. Do not put sensitive documents into an ordinary planning note just to keep everything in one place.
After requesting an opinion
- Continue tracking relevant changes in housing, household and work.
- Respond to requests for further information within the stated timeframe.
- Review the opinion against the facts it assumes.
- Keep tax return, election and payment deadlines on a separate calendar.
- Ask whether a material change requires a new assessment or further communication.
ExitCanada’s planner can help organize the questions you bring to this process. It does not submit NR73, obtain CRA approval or determine your tax residence. Use the residency guide to build the underlying factual record first.
Official sources
Sources checked 12 September 2026. Check the current authority guidance and tax-year-specific forms before acting.
General planning information, not a personal tax or immigration determination. Your facts and the rules in each country control the outcome. Obtain qualified advice for decisions, calculations and filings specific to you.
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