W and H, wife and husband, are citizens of Canada. They do not have U.S. citizenship nor do they hold a U.S. green card. They maintain homes in both Quebec and Florida. W and the couple’s minor children spend about nine months each year at the Florida home, and the children attend school in Florida public schools. W and the children spend the summer months (80 days) in Quebec. H, who owns a construction company in Quebec, spends most of the year in Quebec, but makes several trips to Florida each year, aggregating 70 days annually. H’s income comes from the construction business. W owns several farms in Quebec which are rented to tenants and produce a significant amount of rental income. H & W do not file a joint return in the U.S.
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