Questão jurídica principal
Whether the taxpayer remained subject to unlimited tax liability in St. Gallen from 16 July to 31 December 2007
Decisão extraída
Yes. His prior tax domicile in Z./SG continued because he proved only a temporary foreign stay and did not prove a new domicile in another canton or abroad.
Fundamentação extraída
The burden of proving a relocation lay on the taxpayer once the prior domicile and temporary nature of the foreign stay appeared highly probable. His evidence did not establish a new center of life in Canada, Mexico, the USA, or A./ZH.