What are the material factors used to determine whether an individual has a fiscal residence in both countries?

In The Queen v. Reeder, [1975] C.T.C. 256 (F.C.T.D.), Mahoney J. listed some of the factors which have been found to be material in determining the question of residence as follows: 13 While the defendant here is far removed from the jet set, including any possible imputation of a preconceived effort to avoid taxation, the factors which have been found in those cases to be material in determining the pure question of fact of fiscal residence are as valid in his case as in theirs. While the list does not purport to be exhaustive, material factors include: (a) past and present habits of life; (b) regularity and length of visits in the jurisdiction asserting residence; (c) ties within that jurisdiction; (d) ties elsewhere; (e) permanence or otherwise of purposes of stay abroad. The matter of ties within the jurisdiction asserting residence and elsewhere runs the gamut of an individual's connections and commitments: property and investment, employment, family, business, cultural and social are examples, again not purporting to be exhaustive. Not all factors will necessarily be material to every case. They must be considered in the light of the basic premises that everyone must have a fiscal residence somewhere and that it is quite possible for an individual to be simultaneously resident in more than one place for tax purposes.