In a case before the Tax Court of Canada (TCC), decided on 22 July 2005 (Yoon v. The Queen), a Canadian citizen, Yoon, born in Korea (Rep.), claimed that she was no longer a resident of Canada in the 2001 tax year and, therefore, her employment income was exempt from taxation in Canada under the Canada-Korea income tax treaty of 10 February 1978.
(a) Facts. The taxpayer grew up in Korea and attended university there. In 1975, she moved to Canada, married, became a Canadian citizen and …