The taxpayers were middle-aged "all American" certified cost estimate professionals, with no significant previous exposure to Canada, who came to Alberta under two-year contracts (later extended by two years) to work on the Syncrude project. Although they acquired and modestly furnished apartments in Alberta, they maintained their substantial homes in the U.S. where their families stayed (other than for short visits to Alberta) and otherwise maintained their social ties and financial assets in the U.S. After finding that the taxpayers were not ordinarily resident in Canada, Boyle J.