Before going on to find that the taxpayer was not ordinarily resident in Canada, Bowman C.J. stated (at p. 237):
"The use of the word 'includes' in subsection 250(3) seems to imply that there could be a third (undefined) category of Canadian resident who is neither deemed under subsection 250(1) to be a resident of Canada nor 'ordinarily resident' within the meaning of subsection 250(3). It is not clear just what the characteristics of such a form of residency might be."