The taxpayer, who had been a resident of Canada for six years, moved to a job in Saudi Arabia for the three taxation years in question, with most of his salary being remitted to his family who stayed in Canada and with the taxpayer returning to Canada for 30 vacation days a year and maintaining various other connections with Canada. He continued to be resident in Canada (and was liable for gross negligence penalties for not reporting his income from his job in Saudi Arabia).
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