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The Hungarian subsidiary arranged the rental of a furnished three-bedroom apartment for Roman and his family. Roman planned to look for a house to purchase

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The Hungarian subsidiary arranged the rental of a furnished three-bedroom apartment for Roman and his family. Roman planned to look for a house to purchase when his family arrived later, but prospects for nding a suitable house were not great, due to a very heavy demand. If a suitable house were not found, the apartment would be adequate for the family. As a result of the slow real estate market in Canada, the family home could not be sold at an acceptable price. The family decided to rent the house for the period that they were living in Hungary. Finally, in July 2011, tenants were found to rent the house and the fln'niture on a one-year lease. Roman's wife and children left Canada to join him on August 1, 2011, after selling the second car. Roman and his wife own a cottage in Canada which they plan to live in during a one-month vacation in each of the summers that they will be away, starting with the summer of 2011. This would allow the family to visit with relatives and friends who remained in Canada. Roman retained his golf club membership in Canada, because he did not want to lose the high initiation fee that he had paid fairly recently to become a member. However, he did resign from two Canadian business clubs that required annual membership fees. He joined similar clubs on his arrival in Hungary. Roman was paid in Hungarian c1n'rency by the subsidiary, which deposited his pay directly into a bank account which he opened in Hungary. He retained his RRSP invested in Canada and his investment portfolio containing mostly Canadian securities. He also had to retain a bank account in Canada into which the rent on the house was deposited by the tenants. The tenants were instructed to withhold and remit to the Canada Revenue Agency 25% of the agreed monthly rental, as required on payments to non- residents. Required: Advise Roman on how to le his 2011 tax retlnn. Evaluate thoroughly and in detail the alternatives in the residence issue as they relate to this fact situation. Present your answer by discussing each degree of residence and its tax consequences as it applies to this fact situation. Provide your advice, in conclusion, after weighing the relevance of the facts you have considered

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