Principal Issues: 1. What is the meaning of the word "Canada" as used in the Act? 2. Can a taxpayer be resident in Canada and in a province at the same time? 3. Is a person working in the private sector liable to tax in the province and in Canada?
Position: 1. "Canada" is defined in the Act. 2. A taxpayer is generally factually resident in Canada and in a province concurrently. 3. Every person resident in Canada at any time in a taxation year shall pay an income tax on their taxable income for each taxation year,.
Reasons: 1. N/A 2. The Act and provincial legislation 3. S. 2(1) of the Act.