I think I know the answer, but am attempting to be proofed wrong, and saving a client $3,000
Husband is Canadian (citizenship by birthparents), spouse is American. They only lived in the USA until August 1, when they moved to Canada. Immigration is still processing her permanent resident status, so right now she has no status, but has been physically present in Canada with her spouse and 5 children. They have otherwise broken US residential ties, their permanent home is here, etc.
She does not have a social insurance number, and is in the process of applying for a ITN number so that she can pay the Receiver General $3,000.
Anything I can hang my hat on for the IRA withdrawal not to be taxed in Canada?