Shih v. The Queen, 2000 DTC 2072 (TCC) -- summary under Subsection 2(1)

The taxpayer, who was a pharmacist permanently employed in Taiwan, was found not to have become a resident of Canada notwithstanding that he had entered Canada and applied for permanent residence under the entrepreneurship program and had bought a house in Regina at which his wife and children resided. The taxpayer did not change his life pattern with respect to his continuous employment and social connections in Taiwan (including caring for his parents there and spending over ¾ of his time there); and Mogan TCJ accepted the taxpayer's explanation that the Regina connection had been established in order to have his children educated in North America.