24, 2018 and December 5, 2018. The Act provided for the following changes: The period required for physical presence in Canada was reduced from 1,460 days over six years to a total of 1,095 days over the five years immediately prior to submitting an application for citizenship. The requirement that a person intend to reside in Canada if granted citizenship was repealed. The adult maximum age limit applicable for the requirements to demonstrate adequate knowledge of one of the official languages is now applicable to those under 55 years of age, rather than by those under 65. The requirement to file income tax returns was clarified, so that persons must provide such returns for three years within the five-year period before applying for citizenship. "Statelessness" was added to the available grounds for the Minister to exercise his or her discretion in granting citizenship to any person "to alleviate cases of special and unusual hardship or to reward services of an exceptional value to Canada." The prohibition on receiving a grant of citizenship, or taking the citizenship oath, while serving a term of imprisonment was broadened to include being held under any form of incarceration. The power to revoke citizenship on grounds of national security was repealed. The provision specifying that a person whose citizenship is revoked reverts to being a foreign national was amended to provide that the person's status reverts to that of a permanent resident. The Minister was granted the power to seize or detain any document submitted for the purposes of the Act if there are reasonable grounds to believe the document was fraudulently or improperly obtained or used. Transitional provisions provided for certain of the 2014 amendments to be deemed to have never had effect. Judicial review of Citizenship Act provisions Definition of "residence requirement" There have been several court decisions dealing with the subject of Canadian citizenship. In particular, the interpretation of the 3-year (1,095-day) residence requirement enacted by the 1977 Citizenship Act, which does not define the term "residence" and, further, prohibits an appeal of a Federal Court decision in a citizenship matter to the Federal Court of Appeal or the Supreme Court, has "led to a great deal of mischief and agony" and generated considerable judicial controversy. Over the years two principal schools of thought for residence have emerged from the Federal Court. Early on, Associate Chief Justice Arthur L. Thurlow in Papadogiorgakis