What is the legal test for “residence” in a hotel?

In my view, no hard and fast line in terms only of length of stay can be drawn as a matter of law. A traveller or tourist may stay in a hotel for a few weeks without being said to “reside” there, just as a person may “reside” in his or her own house for a short period and then find it necessary for some reason to stay elsewhere for an extended period. As the cases decided under the Income Tax Act concerning the phrase “ordinarily resident in Canada” make clear, many factors, in addition to the length of stay, are involved in determining “residence” — whether one lives out of a suitcase or brings all one’s possessions to the unit; whether one establishes roots and connections in the local community or remains only a sojourner; whether one is accompanied by family and is employed permanently or semi-permanently in the area; location of bank accounts and other records; etc.: see Thomson v. Canada (M.N.R.) 1946 CanLII 1 (SCC), [1946] S.C.R. 209.