Sampson - B.C. Supreme Court finds that a Calgary executive with a large B.C. home had his “principal place of residence” in B.C.

The taxpayer, described as “a wealthy CEO of an international energy company,” maintained a 600 square foot apartment within three blocks of the Calgary headquarters of his employer, but spent over half of his Canadian time in B.C., where there was a 10,000 square foot home (near his parents’ home) owned by his wife and where their social life was centered. Gaul J found that although the taxpayer was resident both in B.C. and Alberta, B.C. was the taxpayer’s “principal place of residence” under the tie-breaker rule in Reg. 2607, so that he was subject to B.C. income tax. Not only did he spend somewhat more time there, but he also “had a much closer and profound personal tie” with B.C.

Neal Armstrong. Summary of Sampson v British Columbia, 2018 BCSC 1503 under Reg. 2607.