The taxpayer, who stayed in Michigan in a condominium owned by her friends without paying rent and who visited, on a weekly basis, her husband and children in Windsor, did not have a permanent home in either Canada or the U.S. She had a centre of vital interest both in Canada (where she had closer personal ties notwithstanding that most of her friends were in Michigan) and in the U.S., where she earned her living. However, her habitual abode was in the U.S., so that under the tie-breaker rule in Article 4, paragraph 2(b), she was a resident of the United States.
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