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Thanks a lot for a detailed response!
After several back and forth to close loose ends oversea and to comply with the RO my parents have moved here permanently. They been here for almost year and a half. To be honest they need the card only for travel reasons, otherwise we would just wait to the citizenship….
Thanks for the idea to be some sort of “guarantor”. I never thought about it….

My only question for if you don’t mind. My dad have submitted tax return for 2024. The NOA is not yet issued as he’s been audited. Not a big deal as it’s in process and will be finalized soon. We do have audit letter not NOA….would sending this letter be too risky as an evidence (with explanation)?
Thanks a lot again!

I am no expert and not qualified to give advice. I doubt an audit letter would be risky but frankly I am not the one to say.

In the situation you describe, it really is a don't overthink things scene.

A PR who is well established, settled in Canada for more than a year, and who is in compliance with the RO, should have almost nothing to worry about.

Technically two bank statements showing the PR's address in Canada would suffice to make a complete application. If one is from early 2024 and the other very recent, best guess is that will be sufficient to have a new PR card issued unless a processing agent or officer sees some reason to doubt the travel history (so it is important to be precisely accurate and complete, as best as possible).

If they have cards showing they have current health care coverage, copies of those would be good things to submit (a valid health card is evidence of receiving benefits from Canadian government programs). This is better evidence than a bank statement (not as good as evidence of working a job in Canada).

However, if they barely meet the RO, and they are relying on numerous short visits here to count, they might NOT qualify for automated decision-making and their applications could be considered complex, resulting in a significantly longer processing time. It might help to wait a month or two more to make the applications, and if they currently barely meet the RO it would be wise to not travel abroad anytime soon anyway.
 
Please read the chain before making such assumptions. After @Ponga suggested that the evidence doesn’t need to cover the entire period I wondered if the healthcare eligibility and related stuff would be a good second piece as a proof of government benefit. They been here for 431+ days man…
I will appreciate if don’t reply to my chain anymore. Not an ideal and unnecessary conversation. Thank you
Since you seem a tad bit prickly, I’ll give you a heads up

I used to work for the CRA . If they’ve pulled your return for audit , you have more things to worry about

People think returns are audited randomly ?

There’s ALWAYS a reason returns are pulled

I’d appreciate you don’t reply to this as you mentioned
 
I am no expert and not qualified to give advice. I doubt an audit letter would be risky but frankly I am not the one to say.

In the situation you describe, it really is a don't overthink things scene.

A PR who is well established, settled in Canada for more than a year, and who is in compliance with the RO, should have almost nothing to worry about.

Technically two bank statements showing the PR's address in Canada would suffice to make a complete application. If one is from early 2024 and the other very recent, best guess is that will be sufficient to have a new PR card issued unless a processing agent or officer sees some reason to doubt the travel history (so it is important to be precisely accurate and complete, as best as possible).

If they have cards showing they have current health care coverage, copies of those would be good things to submit (a valid health card is evidence of receiving benefits from Canadian government programs). This is better evidence than a bank statement (not as good as evidence of working a job in Canada).

However, if they barely meet the RO, and they are relying on numerous short visits here to count, they might NOT qualify for automated decision-making and their applications could be considered complex, resulting in a significantly longer processing time. It might help to wait a month or two more to make the applications, and if they currently barely meet the RO it would be wise to not travel abroad anytime soon anyway.
Thanks a lot again!

Just to give some clarity on the overall presence.
They have got a total of almost 800 days in the past 5 years. Out of these days 1 year and 5 months is a full time permanent life in Canada. Thousands of people are on the same path.
I don’t feel like they have outstanding circumstances and seem like they line up well with the days requirements.

Thank you for sharing your thoughts!
 
Since you seem a tad bit prickly, I’ll give you a heads up

I used to work for the CRA . If they’ve pulled your return for audit , you have more things to worry about

People think returns are audited randomly ?

There’s ALWAYS a reason returns are pulled

I’d appreciate you don’t reply to this as you mentioned
as per an old saying: You can leave a place (CRA in your case) but the place (CRA…) would never leave you….
 
Please read the chain before making such assumptions. After @Ponga suggested that the evidence doesn’t need to cover the entire period I wondered if the healthcare eligibility and related stuff would be a good second piece as a proof of government benefit. They been here for 431+ days man…
I will appreciate if don’t reply to my chain anymore. Not an ideal and unnecessary conversation. Thank you
Don't take it personally, just some people have obsessions. Some people are obsessed with sex, some with the idea that someone, somewhere received healthcare they shouldn't.

The difference is I don't post about my obsession all the time.
 
Don't take it personally, just some people have obsessions. Some people are obsessed with sex, some with the idea that someone, somewhere received healthcare they shouldn't.

The difference is I don't post about my obsession all the time.
I know right….it seems to be both obsessions you noted. Has been f…..g my brain to hold me accountable for others who f….d the system
 
Stop overthinking. They ask for two pieces of evidence. They provide some examples of the types of things. Provide the two pieces of evidence. Stop trying to figure out how to plug gaps when they haven't asked you to.

To be fair the instructions are worded a bit confusingly in some places. See https://www.canada.ca/en/immigratio...newal-change-gender-identifier.html#appendixA

> Canada Revenue Agency (CRA) Notice of Assessment for the five (5) years immediately before the application

At a glance that reads to me like you need to submit give NoAs that cover the five years before the application, and since an NoA only covers a year, that would be five NoAs to submit.

The correct interpretation of course is that they mean only an NoA from the last five years should be used as a piece of evidence, as older ones won't cover the required period. But this is a better wording:

"Canada Revenue Agency (CRA) Notice of Assessments, assessing one of the five (5) years that are immediately before the application"

In fact, I'd also interpret this wording to mean to cover the entire period: it's just that you should find two pieces of evidence that covers each and every day of the five years.

> You must provide copies of 2 pieces of evidence that can show you have met the residency in Canada in the five (5) years immediately before the application

Better if it said,

"You must provide copies of 2 pieces of evidence that each can show that you have been resident in Canada at some point in time in the five (5) years immediately before the application."
 
To be fair the instructions are worded a bit confusingly in some places. See https://www.canada.ca/en/immigratio...newal-change-gender-identifier.html#appendixA

> Canada Revenue Agency (CRA) Notice of Assessment for the five (5) years immediately before the application

At a glance that reads to me like you need to submit give NoAs that cover the five years before the application, and since an NoA only covers a year, that would be five NoAs to submit.

The correct interpretation of course is that they mean only an NoA from the last five years should be used as a piece of evidence, as older ones won't cover the required period. But this is a better wording:

"Canada Revenue Agency (CRA) Notice of Assessments, assessing one of the five (5) years that are immediately before the application"

In fact, I'd also interpret this wording to mean to cover the entire period: it's just that you should find two pieces of evidence that covers each and every day of the five years.

> You must provide copies of 2 pieces of evidence that can show you have met the residency in Canada in the five (5) years immediately before the application

Better if it said,

"You must provide copies of 2 pieces of evidence that each can show that you have been resident in Canada at some point in time in the five (5) years immediately before the application."

I've been thinking this over.

While the instructions are quite clear, it would probably be helpful if they included something like the following verbiage in the instruction guide (Guide IMM 5445 to be explicit):

"You do not need to cover every day of the residence period. Proof like a zero dollar Canada Revenue Agency (CRA) Notice of Assessment that covers one year is sufficient as one piece of evidence. A rental agreement covering a single day is also sufficient as one piece of evidence."
It won't help everyone (since not everyone bothers to read the instructions). But might reduce the number of questions a bit...

There is little if any need for clarification. These particular instructions, in the Guide for a PR card application, in the appendix in particular, are not confusing, notwithstanding some confusing answers given in the forum. (Which is not to ignore other IRCC information and instructions that are flawed, some confusing).

It warrants noting that the reference to a CRA NOA (it is a singular reference by the way, referring to the CRA "Notice of Assessment" singular, not plural) is just an EXAMPLE, one example of many, of what can be submitted as an item of "evidence that can show" the RO is met, a document that can be one of two items submitted.

There is NO instruction to include a copy of any NoA, let alone more than one, let alone enough to cover five years. A CRA NoA is simply listed as an example of something that can be submitted to show RO compliance.

Reminder: For a PR who meets the RO based on actual presence in Canada, the instruction is simple and straightforward: include "2 pieces of evidence that can show you have met" the RO, and that is sufficient to make a complete application. That is the instruction.

Only if taken utterly out of context could the NoA example be interpreted to require a document or documents that covers five years . . . out of context in regards to the instructions as a whole, and out of context in regards to what a NoA is, and out of context in regards to the RO itself . . . and that is apart from the fact that the reference itself, again, is singular not plural.

Moreover, regardless how IRCC describes this example, there is no doubt that a single CRA NoA can be evidence of presence/residence in Canada, meaning it is evidence that can show the RO is met. So, even if just one NoA did not comport with someone's interpretation of the example, as stated, at the very least one NoA would still suffice as one item of evidence that can show the RO is met. (Another reminder: the list of examples includes reference to "other documents" . . . so even just a single T4, or any other communication from CRA to the PR, could be one of the two items submitted.)

The fact that this forum has entertained more than a few confusing "interpretations" does not mean the instructions are confusing. Like other open internet forums, more than a little that is off-the-mark, and quite a bit well off-the-mark, flows all too freely here.

In any event . . . no need for PRs (those who meet the RO based on days physically present in Canada) to be at all confused about what supporting documents can be submitted to make a complete application.

For those whose RO compliance is questioned, in contrast, follow the instructions in IRCC communications.
 
I agree with most of what you write above, but there are a couple of important points where I must respectfully disagree with you.
There is little if any need for clarification. These particular instructions, in the Guide for a PR card application, in the appendix in particular, are not confusing
So the specific instruction that I would point out to be confusing is this,

> You must provide copies of 2 pieces of evidence that can show you have met the residency in Canada in the five (5) years immediately before the application

The plain reading of this is that those two pieces of evidence should show that you have met the residency obligation in the five years immediately before the application.

Since a few paragraphs above, this is defined (in the most common case) as:

> you must have been physically present in Canada for a minimum of 730 days within the past five (5) years.

It's too easy to ready these two in combination as saying that you must show two pieces of evidence showing that you have been physically present in Canada for a minimum of 730 days within the past five years.

I.E. that every day of the 730 minimum must be covered. Which is easy if you have an unbroken more than two year period of never leaving Canada that coincides with a couple of NOA periods. But then it becomes a bit contradictory in what happens if you can't show coverage for each day with only two pieces of evidence due to things like frequent travel.

(The answer from this forum of course is that IRCC knows from CBSA and likely US CBA records that you're covered anyways, and so you just show two pieces of evidence even if the 730 days aren't fully covered, and trust that IRCC knows the minimum has been met regardless. But that's the part not clear from the instructions. And if you need to submit more than two pieces of evidence anyways, it starts to make sense in an applicant's head to submit extra to cover the entire five year period if you have that buffer to show.)
It warrants noting that the reference to a CRA NOA (it is a singular reference by the way, referring to the CRA "Notice of Assessment" singular, not plural)
But the difference of it being singular vs plural is down to a single letter (a missing s). And it's the one of two singular bullet points in the list where the remaining bullet points are all plural,
  • employment records or pay stubs;
  • bank statements;
  • Canada Revenue Agency (CRA) Notice of Assessment for the five (5) years immediately before the application
  • evidence that you received benefits from Canadian government programs;
  • rental agreements;
  • club memberships;
  • or any other documents that prove you met your residency obligation.
At least they group the two singular ones together. And, of course, if the NOA point was actually plural, it should at least look like this,

> Canada Revenue Agency (CRA) Notice of Assessments for the five (5) years immediately before the application

Reading the pluralized version makes the point of confusing clearer - the statement by itself is ambiguous as to whether or not ALL NOAs for the previous five years are needed.

But I think the singular version is a bit clearer on this. So at least they could make it more verbose that this is singular, like

> a Canada Revenue Agency (CRA) Notice of Assessment

or

> at least one Canada Revenue Agency (CRA) Notice of Assessment
 
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> You must provide copies of 2 pieces of evidence that can show you have met the residency in Canada in the five (5) years immediately before the application

The plain reading of this is that those two pieces of evidence should show that you should show that you have met the residency obligation in the five years immediately before the application.

No, that is not a plain reading of that instruction . . . and to be clear, even if the obvious typo is corrected (I assume you did not actually mean "should show that you should show . . . ")

Overall: instructions should be read with a focus on understanding what they mean, not to support this or that interpretation.

And instructions should not be read out of context and for sure not in a manner that obfuscates.

Please do not try to make this overly complicated for forum users. For many PRs, English or French can be a challenge even in ordinary terms, let alone in bureaucratic forms and instructions. There is plenty enough posted here, as is, that is confusing, misleading, even misinformation.

This is an instruction stating what is required to make a complete application, not what would be required to prove that the PR had been physically present in Canada sufficient to meet the RO. Context matters.

There is no doubt, for purposes of submitting supporting documents to show RO compliance sufficient to make a complete application, for PRs who meet the RO based on days actually present in Canada, the instructions are asking for ONLY two items of evidence that respectively show presence or residence in Canada during the relevant five years. That's it.

There is no doubt, either, that a CRA NoA, a single NoA, is in fact (an obvious fact) an item of evidence the PR has had residence in Canada. Even if the NoAs was not on the list, this would still be obvious, and a NoA (a single NoA) could still be one of the two items of evidence the PR submits with the PR card application.

Leading to
Reading the pluralized version makes the point of confusing clearer - the statement by itself is ambiguous as to whether or not ALL NOAs for the previous five years are needed.

Needed for what? Again, context matters.

The way IRCC lists examples, just some examples of evidence to be submitted, it cannot reasonably be understood (let alone be read to actually mean) that NoAs for all five years is what is needed to constitute ONE item of evidence that shows presence or residence. And that is what it is needed to be, just an item of evidence showing either presence or residence in Canada (during the relevant time of course).

Again, even just a T4 form (displaying the PR's name and Canadian address) is an item of evidence that shows presence or residence in Canada. A single NoA is for sure an item of evidence that shows presence or residence in Canada.

The list of examples is NOT a list of what is required to prove RO compliance (sufficient to meet the beyond a balance of probabilities standard of proof that the RO was met) . . . it is a list of types of items, individual items of evidence, that can show RO compliance. This means an item that shows either presence in Canada (direct evidence of some period of time IN Canada) or residence in Canada (indirect evidence of presence, evidence that makes it more likely the PR has been in Canada).

Again, a single NoA is clearly an item of evidence that can be used to show RO compliance (again, in that it shows residence in Canada). If RO compliance is an issue being litigated, the finder of fact would be obligated to consider a single NoA as relevant evidence supporting the claim of presence in compliance with the RO.

So no matter how you parse the list of examples, it would make NO sense to read it that ONLY all NoAs for five years are needed to constitute one of the two items ("pieces") of evidence needed to provide "supporting" documents.

For another example, it would be ludicrous to say that a document showing a club membership in Canada meets what is "needed" to constitute one of the two items of evidence for showing RO, but a CRA NoA does not unless NoAs for all five years are submitted. Utterly ludicrous actually.

Again, the instructions should be read to understand them, and no, reading the example of a CRA NoA to mean it takes all NoAs for five years is not reading the instructions to understand them.

It's not confusing . . . despite the occasional resurgence here of noise otherwise.

Summary (for others, and what matters): For a PR who meets the RO based on days actually present in Canada, no need to wrestle with this: a single NoA can count as one of the two pieces of evidence needed to make a complete PR card application. Of course, obviously, just like any bank statements, club memberships, pay stubs, T4s, or such, the content of the document needs to show the PR's presence or residence in Canada sometime during the relevant five years.
 
and to be clear, even if the obvious typo is corrected (I assume you did not actually mean "should show that you should show . . . ")
Ah sorry about that, good catch, just fixed.
No, that is not a plain reading of that instruction . . .
Uh, yes, it is?

I would be willing to go down a bit here, and concede that there might be multiple plain readings, one of which is mine and another is yours. But this would only prove my point - if the instructions have multiple plain readings, then it's easy to see how some could get confused - if they go with the wrong interpretation.
And instructions should not be read out of context and for sure not in a manner that obfuscates.

Please do not try to make this overly complicated for forum users. For many PRs, English or French can be a challenge even in ordinary terms, let alone in bureaucratic forms and instructions.
I agree in full with this. I'm not arguing to the forum that folks should be trying to cover every day or whatnot - I agree with your points and that your interpretation is in fact the correct one - I'm just stating that the instructions themselves are confusing and open to interpretation (including wrong but reasonable ones). The whole "if in doubt, follow the instructions" bit is still the best advice, even in this case, but it's also a bad showing for IRCC when folks need to be given guidance on what the instructions actually mean.

Now, if you need a legal degree or some sort of legal background and experience to properly read and interpret the instructions - fine, I don't have that. I'm not qualified and am happy to go along with those who have the experience to interpret it properly. (Although if this is truly the case I also would question whether or not these instructions should be intended for the general public.)

But, consider this. I'm a native English speaker. Not only that, I took IELTS general and got a perfect score in reading. I'm not bragging here, just saying that if someone who knows English as well as I do can get confused on reading the instructions, then it should be a given that these instructions could easily be equally if not more confusing for those who have more challenges with the language.
I hope that bifurcating the discussion claiming the instructions for PR card applicants are confusing is not intended to make things more confusing.
That certainly wasn't my intention. I do see your point though. To keep things simple, I'm happy to have your post on the other thread as the final say and continue all discussion here in just one thread.

I should point out that it may not just be me. We have another forum member - one of the first to helpfully correct my misinterpretations on this very subject in fact - who seems to have at least implicitly agreed with me that the instructions are confusing, on the other thread here https://www.canadavisa.com/canada-i...noa-for-residency-proof.874461/#post-11108208
Unfortunately I think IRCC doesn't mind having these ambiguous and unclear instructions - either because ...
If we really care this much about this point (are the instructions on IRCC's guide for this point confusing or unclear) it might be worth seeing what other forum members think. If on the one hand, only one or two out of thousands feel it's unclear and most get the correct meaning right away, then it just might be a thing with those one or two. On the other hand, if even a significant minority of folks get it wrong (or would have gotten it wrong without the guidance of senior forum members) then it's a hint that the writing by IRCC really is unclear.
 
First, some repetition to keep what's important forefront . . .

Summary (for others, and what matters):

For a PR who meets the RO based on days actually present in Canada, no need to wrestle with claims the instructions about what supporting documents need to be submitted are confusing:
A single NoA can count as one of the two pieces of evidence needed to make a complete PR card application. Of course, obviously, just like any bank statements, club memberships, pay stubs, T4s, or other such items evidencing presence or residence in Canada, the content of the document needs to show the PR's presence or residence in Canada sometime during the relevant five years.​

The rest of this is an aside.

. . . just saying that if someone who knows English as well as I do can get confused on reading the instructions, then it should be a given that these instructions could easily be equally if not more confusing for those who have more challenges with the language

There are plenty of statements in IRCC's instructions and its other information for PRs that is confusing, and a lot more that is very broad including some that is overly broad and some that is overtly vague.

More than a few statements in the instructions are outright NOT accurate. Instructions for the PR card application specifically state, multiple times, that a PR "must" be in compliance with the PR Residency Obligation to be eligible for a PR card. That is simply NOT true. Even a PR who has been issued a Removal Order for a breach of the RO is not only eligible for a PR card but entitled to one so long as there is a right of appeal. And, in the very instructions that repeatedly state that to get a PR card the PR must be in RO compliance there are instructions about how to apply and get a PR card when not in RO compliance.

The point has been made before, deserves repeating, warrants repeating with emphasis:

Overall: instructions should be read with a focus on understanding what they mean, not to support this or that interpretation.

Indeed, at the risk of sliding into linguistics, straying well beyond the scope of what is practical (slipping into the pedantic one rather rude forum participant has emphatically insulted), instructions for IRCC's bureaucratic forms are not statutory provisions, not regulations, not administrative rules, and even though the difference is subtle and may not be obvious to many, approaching the instructions through the lens of interpretation is not the same as reading to understand. There is a reason why the Federal Courts do not have authority to interpret particular terms used by an administrative agency (the courts' have authority to determine if the agency's interpretation is reasonable/unreasonable, and on occasion the FCs have suggested this or that interpretation, recognizing that what such terms means is for the agency to decide).

Leading to . . .
Now, if you need a legal degree or some sort of legal background and experience to properly read and interpret the instructions - fine, I don't have that. I'm not qualified and am happy to go along with those who have the experience to interpret it properly. (Although if this is truly the case I also would question whether or not these instructions should be intended for the general public.)

Actually jurists (lawyers, judges, legal scholars, others whose profession is in the law), at least most jurists, do not have the background, experience, or expertise to read and understand bureaucratic forms and instructions much better than most others who are well informed, as well as being proficient in the language (generally). Some will, but that will be rooted in practical experience dealing with the particular administrative agency, their familiarity with that agency's terminology and manner of stating things. This is a big, big part of why Federal Court judges do not have the authority to interpret an agency's use of particular terms.

There are examples aplenty. A salient one in PR card and PR TD applications is the statement, in the appendix regarding new PRs:

If you have been a permanent resident for less than five (5) years
  • you must show that you will be able to meet the minimum of 730 days of physical presence in Canada within five (5) years of the date you became a permanent resident.
Most of us participating in the forum, in regards to discussions related to PR status, easily understand that this does not mean the PR needs to document how they will in fact be present in Canada enough days to meet the RO within the first five years. No need to say where they will be working or living, for example, no need to describe plans for staying in Canada.

It just means that there must be enough days left on the calendar, before the fifth year anniversary of landing, that when added to days already in Canada they total at least 730. Or, as many here astutely observe, it just means the PR's travel history shows they have not been outside Canada for more than 1095 days since landing.

Compare this to the requirement that a citizen sponsoring a spouse's family class PR application show they will relocate to Canada, which does require some details about their plan to settle here in Canada. To understand (not interpret but understand) these respective instructions demands seeing them far more through the lens of understanding-in-context than it does linguistic or legalistic interpretation.

Parsing these instructions can be as likely to lead one astray as it is to illuminate what IRCC is asking for.

Which leads back to

> You must provide copies of 2 pieces of evidence that can show you have met the residency in Canada in the five (5) years immediately before the application

The plain reading of this is that those two pieces of evidence should show that you have met the residency obligation in the five years immediately before the application.

Forgive me, please, for I will (reluctantly) indulge in just a bit of parsing, for illustrative purposes: There is a difference between what something "can" show (which is what the supporting documents need to do) versus what "does" or "will" show. Your so-called "plain reading" is the latter.

Analogy: a fingerprint at the scene of a crime is an item of evidence that can show (be evidence of) a particular individual's culpability, because it shows the individual's presence at the scene, but it will not, does not, show that individual is the culprit. More evidence than a single fingerprint is needed to do that.

This is why I tried, in a previous post, to highlight the importance of understanding what a supporting document is needed for. No single document, and indeed no two documents combined, are enough to "show [the PR has] met the residency obligation in the five years immediately before the application."

That alone should be enough to make it clear the instruction is not asking for two documents (just two "pieces of evidence") that "show that you have met the residency obligation," that is, not asking for the impossible (it being impossible to show RO compliance with just two documents).

The instruction is clearly, unequivocally, saying the PR needs to submit two pieces of evidence, each piece being a document that can show RO compliance . . . that is, show presence in Canada (which is direct evidence of days getting credit toward RO compliance) or residence in Canada (indirect evidence of being in Canada).

All of which is well beyond the scope of the TLDR (too long, didn't read, or don't read) crowd that is so prevalent (not just here), but well shy of a full dive into navigating the nuances (like explaining why the reference to "bank statements" is plural versus the NoA or document showing receipt of government benefits is singular, English major stuff, but not really necessary to understand what is being asked).

But for this particular matter, the matter of what needs to be included in a PR card application to make it complete, there shouldn't be any need to go there. So, I will repeat, and this is true regardless what someone can read into the instructions:

Summary:

For a PR who meets the RO based on days actually present in Canada, no need to wrestle with claims the instructions, about what supporting documents need to be submitted, are confusing:
A single NoA can count as one of the two pieces of evidence needed to make a complete PR card application. Of course, obviously, just like any bank statements, club memberships, pay stubs, T4s, or other such items evidencing presence or residence in Canada, the content of the document needs to show the PR's presence or residence in Canada sometime during the relevant five years.