Pertinent facts are given for a different individual or corporation in each of the parts of this prob-

lem. For each part, indicate whether or not this individual or corporation would be considered a

Canadian resident for income tax purposes during 2021. Explain your conclusion.

A. Brian Palm was born in Kanata, Ontario. In January 2021, after a record snowfall paralyzed

the area, Brian concluded he was not prepared to continue dealing with Ontario winters. He

wound up his Canadian affairs and, on July 31, 2021, he moved to Palm Beach, Florida. He

has vowed to never set foot in Canada again.

B. Gunter is married to Rachel, who is a member of the Canadian Armed Forces serving in

Germany. Except for a brief visit to Rachel's home town of Dartmouth, Nova Scotia, Gunter

has never been to Canada. Gunter is exempt from taxation in Germany because he is the

spouse of a deemed resident of Canada.

C. Sarah is a U.S. citizen living in Bloomfield Hills, Michigan. Most of her personal belongings

are located in her parent's home in that city. However, throughout 2021, she has spent at

least four days of every week living with her boyfriend in Windsor, Ontario. They plan to be

married at some future date.

D. Martha is a U.S. citizen who, until 2021, had lived and worked in Canada as a landed immi-

grant for over 20 years. After winning $1.2 million playing black jack at the Montreal Casino

on August 28, 2021, she left Canada on a two-year pleasure trip that will take her to virtually

every country in the world. Her husband and children, all Canadian citizens, continue to live

at the family home in Laval, Quebec.

E. Bronson Inc. was incorporated in Ontario in 1962. Until 1995, its only director resided in

that province. In that year, the director was replaced by an individual resident in Corning,

New York. All board meetings are held in the United States.

F. Ubex Ltd. was incorporated in Delaware in 1987. Until 2000, all of the directors of the corporation lived in Moncton, New Brunswick. During this period, the board of directors mee

were held in that city. Beginning in 2000, all of the directors have been residents of Green

Bay, Wisconsin, and all of the board of directors meetings have been held in Wilmington,Delaware.