AP 1-10 Residency/Dual ResidencyIndividuals Determine the residency status of the individuals in the following cases....
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AP 1-10 Residency/Dual ResidencyIndividuals Determine the residency status of the individuals in the following cases. Use the tie-breaker rules found in the Canada/U.S. tax treaty where appropriate.
Case A Ty Breaker is a citizen and resident of the United States. He is a professional athlete, a successful entrepreneur, and single. In 2022, he plays for a Canadian soccer team and, as a consequence, he spends 194 days in Canada. Because of his extensive travel, he stores his few personal items in his mothers basement and lives in short-term rentals of hotel suites in both Canada and the United States. His mother lives in Ontario. As he is the sole shareholder of corporations in both countries, and he has offce space in both Canada and the U.S. In previous years, Ty has played for a U.S. soccer team and had spent less than 100 days per year in Canada.
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