Sanctuary – Court of Quebec finds that the acquisition of a secondary residence just outside Quebec was insufficient to change the taxpayer’s Quebec residence

The taxpayer, who testified that “he never developed a strong sense of belonging to Quebec” and that “his best friend … lived in Ontario,” purchased a house in Lancaster, Ontario (90 km from Montreal) in late 2012. After it was rendered habitable, he and his wife spent occasional weekends there, but continued to work full time in Montreal and to live there most of the time.

Davignon JCQ confirmed the ARQ view that the taxpayer continued to reside in Quebec for his 2012 taxation year.

Neal Armstrong. Summary of Sanctuary v. Agence du revenu du Québec, 2020 QCCQ 1903 under s. 2(1).