Plenty of Winnipeg families have one foot in Israel. Some have children who made aliyah, and some spend the coldest months in Tel Aviv or Rehovot. Readers who follow former Winnipegger Bruce Brown know how quickly a second life there can take shape. Long stays raise a quiet question that few people ask until a letter arrives: which country counts you as its tax resident?

Alt text: Families on a Tel Aviv beach with high-rise hotels along the shoreline

For anyone weighing dual residency Canada questions, Cardinal Point Wealth Management has published a plain-language guide to how the rules work. This article walks through the Canadian tests, the Canada-Israel treaty and the paperwork worth keeping. It is general information, not tax advice, and every situation turns on its own facts.

How Does Canada Decide Whether You Live Here?

Canada taxes its residents on their worldwide income. The Income Tax Act does not define “residence,” so the courts and the Canada Revenue Agency have filled the gap. The CRA’s guidance sits in Income Tax Folio S5-F1-C1, effective November 26, 2015.

The folio names three significant residential ties: a dwelling place, a spouse or common-law partner, and dependants. The folio treats these as the ties that almost always count, so keeping one in Winnipeg matters.

Secondary ties are weighed together. The folio’s examples include furniture and cars, Canadian bank accounts, a Canadian passport and provincial health coverage. It also lists memberships in Canadian recreational or religious organizations, which can include a synagogue.

A separate rule catches visitors. Someone who is not factually resident but sojourns in Canada for 183 days or more in a calendar year is deemed resident for the whole year. Any part of a day counts toward that total.

When Can Two Countries Both Claim You?

Dual residency happens when Canada treats you as resident and another treaty country does too. Cardinal Point’s guide points to several groups who often end up here:

1. People with a second home in a warmer place.
2. Landed immigrants who kept ties to their country of origin.
3. Employees on extended foreign assignments.
4. Remote workers whose jobs now cross borders.

The second group is larger than many assume. In 2022, the Federation’s then planning chief told this paper that immigrants made up around a third of the community. The Federation now puts Winnipeg’s Jewish population at 13,940 for 2021. Many of those families still hold homes, accounts or pensions elsewhere.

Israel applies its own residency rules, separate from Canada’s. Anyone with an Israeli home or income should get advice on the Israeli side as well.

How Does the Canada-Israel Treaty Break the Tie?

Canada and Israel signed their current income tax convention on September 21, 2016. Its Article 4 runs through a fixed order of tests for an individual resident in both countries:

There is a step before the table. The folio says you must first be “liable to tax” in each country, which generally means full tax on worldwide income. The onus is on you to show that for the other country.

If the treaty places you in Israel, subsection 250(5) of the Income Tax Act deems you a non-resident of Canada. Cardinal Point notes that a non-resident is generally taxable in Canada only on certain Canadian-source income. Owning a home in both places means the second and third tests often decide the case.

What Paperwork and Pitfalls Should You Expect?

The rules reward people who keep records and move carefully. A few points stand out:

• Form NR73 (leaving) and Form NR74 (entering) ask the CRA for a residency opinion. The folio says that opinion rests only on the facts you supply and does not bind the CRA.
• Cardinal Point adds that there is no legal obligation to file these forms unless the CRA asks, and that filing one could prompt a review.
• Anyone relying on the treaty should expect to show foreign tax returns and assessments.
• Amending past returns to claim non-residence can trigger other costs, such as departure tax.
• Under Article 23 of the treaty, a request for help with double taxation generally must be made within three years of first notice of the action.
• Article 17 generally caps the other country’s tax on periodic pension payments at 15 per cent of the gross amount, with conditions.

What Should You Do Before the Next Long Stay?

Start with a calendar. Log the days you spend in each country, with flights and receipts to back them up.

Next, list your ties on both sides: homes, family, accounts, health coverage and memberships. Seeing them on one page shows which way the tests may lean.

Then talk to someone who works in both systems before you change anything, especially if you draw Canadian pensions while living part of the year in Israel.

Points to Carry Between Two Homes

• Canada generally looks at your ties first, not just your days away.
• The 183-day rule deems visitors resident, so it matters for newcomers too.
• The Canada-Israel treaty settles dual residency in a fixed order, starting with a permanent home.
• Records of days, homes and foreign tax filings are your best defence.

Frequently Asked Questions

Does Synagogue Membership Count as a Residential Tie?

It can. The CRA folio lists memberships in Canadian religious organizations among secondary social ties. Secondary ties are weighed together, so one membership rarely decides a case.

Can I Ask the CRA to Confirm My Residency?

You can file Form NR73 or NR74 for an opinion. The folio says the opinion is based only on the facts you provide and is not binding. Cardinal Point’s guide suggests weighing the risk of a review first.

What If Both Countries Tax the Same Income?

The treaty includes a mutual agreement procedure for double taxation. Under Article 23, an application generally must be made within three years of the first notice of the action. A cross-border adviser can help prepare it.

Can Six Months Abroad Make Me a Non-Resident?

Not by itself. Canada’s test turns on residential ties, and a home or spouse in Winnipeg usually keeps you resident. If Israel also treats you as resident, the treaty tie-breaker then applies.

Planning a Life Across Two Places

A life split between the Prairies and the Mediterranean is a gift many families have worked hard for. A little planning keeps it from becoming a tax dispute. Know your ties, understand the treaty order and get advice in both countries before the next long stay.

By ELENA KNIGHT Rosh Chodesh Sameach! Today is the start of Kislev, when we celebrate the eternal power of light over darkness through Hanukkah, we reflect on our dreams, and, through the month’s connection to the Tribe of Benjamin, we embrace our orderly and honourable side.

Hanukkah is the main feature of Kislev, the holiday when we commemorate the Maccabean Revolt against the Greeks when the Jews regained control over Jerusalem and when we celebrate the miracle of the oil that burned for eight days. This miracle connects with femininity because we women are quite used to pulling things together when it seems like we don’t have it all; how often are we stuck grabbing our shoes as we run out the door, putting makeup on in the car, fixing our hair in the window reflection before we walk into work, and then walking in looking like we had an uninterrupted hour to get ready that morning? Not to mention all of the incredibly strong women who do all this between daycare or school drop-off, reviewing notes from meetings at hockey practice or taking a work call during the drive to a dance competition. The light that burned for eight days when there was only enough for one is a lot like the women who do eight days’ worth of work in just 24 hours.

Looking at the symbolism of light overcoming darkness, we can bring this into our daily lives this month by making this miracle and others public. How often do we do things without asking for any recognition? I say let’s quit that. Let people know when you succeed! It was amazing that you got on the Dean’s List at your university, so tell your friends! Tell your coworkers you got the promotion you’ve been working for! Tell your in-laws that you got the
new job! Publicize your own miracles just like we publicize the Hanukkah miracles by putting our Hanukkiot in the window.

Kislev is called the month of dreams; almost all of the major dreams in Genesis are read in this month’s Torah portions, and Joseph, master of dreams and interpreter of visions, takes centre stage this month. The Talmud teaches that dreams are one sixtieth of prophecy, and since the nights are so long this time of year, now is the time when the inner world, contemplation, and spiritual intuition can be deepened. A great way to connect to the dreamy nature of Kislev could be to keep a dream journal, and take some time to reflect on your dreams. There are many ways dreams can be interpreted, and so many tools to interpret dreams are available in books or online! Common dream symbols are flying (symbolizing freedom or a desire to escape pressure), water (representing your emotional state), and falling (symbolizing a loss of control or feeling ungrounded), and there are thousands of ways that you can use dream interpretation to better connect to your inner world and spiritual life.

This month is associated with the Tribe of Benjamin, which is known for its militarism, bravery, and skill in battle. For us women in the modern day, we can take the militaristic nature of the Tribe and interpret it through adding more order to our daily lives and honour to our personal behaviour. This may be creating a better night routine to support a more consistent sleep schedule or actually taking a full lunch break without any work. Whatever order your life needs, this month would be the perfect time to do it; channel your inner Benjaminite! Adding honour to your personal life can be done through keeping commitments–I recommend a detailed online calendar and to-do list–treating everyone with dignity, keeping your composure in hard moments, and owning your mistakes without shifting the blame. Though these seem like simple tasks, they can be pretty hard to implement when we are faced with tough situations. But what
are we facing in our lives that is as hard as a bunch of Greeks taking over our homeland? Let’s be like the Maccabees this Kislev and face challenges with bravery, knowing that bringing light into our lives will always beat the darkness that tries to sneak up behind us.

The Toronto Raptors host the Boston Celtics tomorrow at Scotiabank Arena, where they’ll try to end a five-game losing streak against their Atlantic Division rivals. They’ll have a rest advantage. Boston plays in Philadelphia on Tuesday before travelling to Toronto, while the Raptors have a day off between home games.

The Raptors vs Celtics prediction comes down to whether Toronto can turn that extra rest into easier baskets. RJ Barrett can attack before Boston’s defence sets, but Jayson Tatum and Paul George give the Celtics two reliable scorers if the game slows in the fourth quarter.

Raptors vs Celtics Date, Tip-Off Time and Where to Watch in Canada

Wednesday is the middle game of a busy stretch for Toronto. The Raptors hosted Memphis on Monday and visit Philadelphia on Thursday. For Boston, the 7 p.m. ET start comes less than 24 hours after its scheduled tip-off against the 76ers.

Recent Form for the Raptors and Celtics

Boston improved to 8–2 with a 117–97 win in Milwaukee on Sunday, its third straight victory. George scored 27 points, and Tatum had 21 points and six assists. The Celtics had also beaten the Bucks 109–102 at home four nights earlier, then won 119–80 in Charlotte in NBA Cup play.

Toronto entered Monday’s game against Memphis at 5–4. Its four-game road trip ended Friday with a 121–107 NBA Cup win in Milwaukee after a 128–109 loss in Denver. Barrett and Alijah Martin each scored 27 points against the Bucks, and Barrett went 9-for-11 from the line. That gave the Raptors a way to score even though Barrett missed all four of his three-point attempts.

Raptors vs Celtics Head-to-Head Record

The Celtics swept the 2025–26 season series 4–0 and have won nine of the last 10 regular-season meetings. They took both games at Scotiabank Arena last season, 121–113 and 112–96. Across the last five meetings, Boston won all of them, averaging 13.8 made threes and winning by 11.2 points.

George arrived in the trade that sent Jaylen Brown to Philadelphia, and Boston added Mitchell Robinson at centre. Last season’s results show how consistently Boston controlled the matchup. Wednesday will test whether Toronto can put more pressure on this Celtics rotation early in the shot clock.

Toronto Raptors Injury Report and Lineup Outlook

Scottie Barnes and Immanuel Quickley missed Friday’s game in Milwaukee. Toronto listed Barnes as questionable for Monday’s game in Memphis with a left groin strain and gave Quickley the same designation for right hamstring tightness. Kawhi Leonard was out for left knee injury management. The next game-specific report will give a clearer picture of who can play Wednesday.

Barnes has the size to defend Tatum without an immediate double-team. Quickley’s status matters at the other end. With him available, Barrett can spend more possessions catching on the move. If Quickley sits, Jamal Shead can initiate the offence and take some of that ball-handling work.

Key Player Matchups for Jayson Tatum and RJ Barrett

Tatum averaged 27.1 points and 7.8 assists through Sunday. When he drives, Toronto’s first decision is how far to bring help off Boston’s shooters. An early rotation can close off his path to the rim, but it also gives George or Derrick White a pass on the perimeter. Toronto’s chances improve if its primary defender can stay in front for longer.

Barrett averaged 21.6 points through Friday. A high screen can give him room to turn the corner before Boston gets a second defender into position. If the Celtics switch a bigger defender onto him, Barrett can try to beat the switch with his first step. His free-throw attempts will offer an early clue as to how much pressure he’s putting on the rim.

Toronto averaged 17.6 fast-break points through Friday, among the league’s best marks. That’s one reason to watch how Toronto gets its first few shots. Barrett attacking a retreating defence suits Toronto better than driving through two defenders late in the clock.

Jakob Poeltl, Mitchell Robinson and the Battle in the Paint

Toronto has outscored Boston in the paint in three of their last four meetings at Scotiabank Arena. The question is whether the Raptors can pair that inside scoring with enough defensive rebounds to get out in transition.

If Poeltl and Robinson share the floor, their positioning on shots could matter as much as their work around the rim. When Poeltl keeps Robinson off the offensive glass, Toronto’s guards can get a head start up the floor. A Boston offensive rebound forces those same guards to find their shooters again.

Robinson can also screen for Tatum. If Poeltl drops towards the rim, Tatum can pull up from the middle of the floor. If Poeltl steps out, the far-side defender has to pick up Robinson as he rolls to the basket

Raptors vs Celtics Betting Odds & Key Markets

Bettors can follow the NBA sportsbook on Stake for the latest Raptors vs Celtics odds, including moneyline, point spread and total points, among others.

Moneyline

The moneyline covers the outright winner, including overtime. Boston is the lean here. Tatum and George give the Celtics two ways to create a shot late in a close game, and either can keep the offence moving if Toronto takes away the first option.

Point Spread

Toronto’s extra day of rest matters when assessing the margin. If the Raptors secure defensive rebounds and turn them into early offence, they can stay close even if Boston controls more of the half-court game. Toronto’s margin on the spread will depend on the posted handicap.

Total Points (Over/Under)

Boston’s five games through Sunday averaged 206.2 combined points. Toronto’s five through Friday averaged 239.8. Those samples give some context for the total. If Toronto can run off misses and get Barrett to the line, the game could be more open. If Boston keeps it in the half court, both teams may have fewer possessions.

Player Props

Tatum’s assists and Barrett’s points are two markets to look for. If Toronto sends help into the lane, Tatum will have perimeter passing options. Barrett’s scoring outlook depends on whether he can get downhill against Boston’s bigger defenders and draw fouls as he did in Milwaukee.

Raptors vs Celtics Prediction and Game Pick

Toronto has the home crowd and enough scoring options to stay in the game, but Boston has the better record, last season’s sweep and Tatum’s star power. The back-to-back is the main reason to expect a close fight.

The recommended pick is the Boston Celtics to win. Canadian fans who want to follow the NBA with Stake can use its live markets and in-play options. Always gamble responsibly and within the legal age in your province.