Roman A. Round was born, raised, and educated in Canada, where he had lived continuously until March

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Question:

Roman A. Round was born, raised, and educated in Canada, where he had lived continuously until March of 2019. Roman was the senior vice-president of International Products Manufacturing Ltd. (IPML), which had its head office in Canada. The corporation transferred him to its Hungarian sales subsidiary to gain some marketing experience in the emerging markets of Eastern Europe. IPML planned to have him return to Canada as its president in about two to three years.

The family home was listed for sale with a realtor in February 2019 with the objective of selling it by the end of the school year in June 2019. Roman left Canada on March 1, 2019 to begin his position in Hungary, after arrangements to obtain a work permit were made by the Hungarian subsidiary. He left his wife and children, who were in elementary school, in Canada, in order for the children to complete the school year. Roman took all of his personal possessions with him when he left. He sold his car, but the family kept a second car registered to his wife for their use in Canada.

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 finding 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 2019, tenants were found to rent the house and the furniture on a one-year lease. Roman's wife and children left Canada to join him on August 1, 2019, 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 2019. 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 currency 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 file his 2019 tax return. 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.