[tharkun__]

Not just stock holdings. Any investments. Except for your primary residence, if you sell it before leaving. So e.g. you're not safe just because you didn't own stock and instead created a real estate investment empire :) If you keep your primary residence and rent it out for example (presumably because you do want to come back and retire in Canada?), then capital gains will accrue from the date you leave Canada.

Fictitious sale = deemed disposition. Same thing. If you can't pay the tax from cash you have lying around you will have to actually sell some of the investments.

Now I do get that selling a business might not be as easy as selling (part of) a liquid stock. But take the real estate example again. Selling your real estate empire seems much harder than selling some of your NVDA shares to pay the tax. If you aren't prepared to sell your business though and you want to hold onto it, why would the government be inclined to believe that you really want to leave and never come back so to speak?

[gndk]

> If you aren't prepared to sell your business though and you want to hold onto it, why would the government be inclined to believe that you really want to leave and never come back so to speak?

No idea. And for a corporation (GmbH) in Germany, it would actually be trivial to track and control this, since the ownership transfer is only possible through a notary public and only becomes legal fact after its published in the public company register. So put a flag on it, and when that transfer shows up, just block it until the exit tax from when you left is paid.

[tharkun__]

I'm not sure we understood the same thing there, given you said "no idea".

My point is that it's very understandable that the government doesn't just trust that you'll pay your departure tax at some future later point, once you've been able to sell your business, in say like 5 years from now, or maybe 7 or like never ;)

I'm not trying to argue that everything is rosy. Just trying to see both sides so to speak. In a non-ideal world. Where not everyone is like you, who'd actually pay his taxes as soon as they were able to sell but they just really really want to leave like now.

[gndk]

Oh, yea I misread that a bit and my "no idea" doesn't really fit there.

I agree with your point that the government generally doesn't trust me to pay at some point in the future. Blocking the ownership transfer for a corporation like I mentioned above would be one way to ensure it though.

But there's no incentive for them to do that.