The Appellant appealed a tax assessment for the 2013 taxation year, which included his total income of $230,828 on the basis that he was a resident of Canada.
The Appellant argued he had severed ties with Canada and was a resident of Ethiopia, where he worked and owned a home.
The Tax Court of Canada applied the factors for determining ordinary residence and found that the Appellant maintained significant ties to Canada, including active bank accounts, RRSPs, a rental property, and frequent visits to his family.
The court concluded that the Appellant's settled routine of life remained in Canada, and dismissed the appeal.