Mr Z will be ordinarily resident in South Africa for the current year of assessment because his return to his homeland is not guaranteed or confirmed because is dependent on a future event being the end of his international career.
I would say Mr Z is ordinarily resident in South Africa. I do understand that he one day intends to return to his country, but that day is undetermined. Also, his stay in South Africa is not a mere casual visit- if it was then we could have argued that he is therefore not ordinarily resident. Robison v COT. He is ordinarily resident in South Africa and would therefore be taxed on his world wide income.
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Mr Z will be ordinarily resident in South Africa for the current year of assessment because his return to his homeland is not guaranteed or confirmed because is dependent on a future event being the end of his international career.
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I would say Mr Z is ordinarily resident in South Africa. I do understand that he one day intends to return to his country, but that day is undetermined. Also, his stay in South Africa is not a mere casual visit- if it was then we could have argued that he is therefore not ordinarily resident. Robison v COT. He is ordinarily resident in South Africa and would therefore be taxed on his world wide income.
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