Discuss the factors the ATO would consider in making their decision

Charles is an accountant and is keen to become a partner in one of the big
international accounting firms. In order to do so he knows that he needs to gain some
international experience. He secures a position with another large accounting firm in
the US with a contract for 18 months. He sells his apartment in August 2014 in
Sydney and buys a similar apartment a few weeks later in New York. He joins the
local gym and rugby team. He volunteers at the Lyons Club on weekends. He has
one brother that lives in the UK and his parents have already passed away. Charles
is not married and has no children. At the end of the 18-month contract, Charles
decides he would like to gain a little more experience and extends his contract
another 12 months.

With regards to the Domicile test, would Charles be considered a resident or not of Australia for the 2014/15 income tax year? Discuss the factors the ATO would consider in making their decision.

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