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Published: April 15, 2020

Last Updated: May 21, 2020

In the 1999 Canadian Income tax case of McFadyen v. The Queen, the taxpayer moved to Japan with his wife, not knowing when and if he would return. He stored his furniture and appliances in Canada and maintained two bank accounts in Canada, owned two houses which he rented out, maintained his membership with a professional association in Ontario, rented a safety deposit box, and maintained an RRSP, credit card and Ontario driver’s license. The Tax Court of Canada concluded that these ties were significant enough to make him ordinarily resident in Canada for the years in question.

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