Canada spent about $3.5 billion in the year ended June 2012 on the refundable GST credit and about $10 billion on the Child Tax Benefit. This may explain why the rules are complex and the CRA is strict. Obviously, Canada can only afford to give these credits to its own residents. This case deals with the test for residence in Canada.
Mr. Bower was from Nova Scotia, where his children and grandchildren lived; he had bank accounts and some property in Canada. But he had moved to Indonesia where he had a spouse and small child. And there, the court concluded, he ordinarily resided, despite occasional visits to Canada.
(A condition of the CCTB is that the child reside with the parent; but there is no condition that the child herself reside in Canada.)