Article IV(2)(a) [of the Canada-United States Income Tax Convention, 1980] provides that a person who has a permanent home available to him in each of Canada and the US will be deemed to be a resident of the country with which his personal and economic relations are closer.
. . . . .
... closer does not mean more numerous. It is a relative not a mechanical or arithmetic concept. Closeness requires that serious attention be focused upon the depth and nature of the personal and economic relations/ties.
Elliott v. R. |
2013 CarswellNat 2540 T.C.C. at para. 67, 72 |