Dysert - Tax Court finds that a four-year work stint in Canada was "sojourning" (i.e., a "temporary" stay)

Three Americans, who were not factually resident in Canada during their four-year stay in Alberta to work on a Syncrude project, were deemed to be resident in Canada under the "sojourning" rule even though Boyle J. accepted that this term referred to a "temporary visit or stay."  However, they qualified for Treaty purposes as resident only in the U.S. under the tie-breaker rule: although their modest Alberta apartments were "permanent homes,"  their centre of vital interests was in the US.

Scott Armstrong.  Summaries of Dysert v. The Queen, 2013 TCC 57, under ss. 2(1) and 250(1)(a), and under Treaties - Article 4.