The appellant, a non-resident of Quebec, retired from an accounting partnership and received a retirement allowance.
The province of Quebec assessed tax on a portion of the allowance equivalent to the percentage of the partnership's total income earned in the province.
The appellant challenged the assessment, arguing the taxing provisions exceeded the province's constitutional authority under s. 92(2) of the Constitution Act, 1867.
The Supreme Court of Canada dismissed the appeal, holding that the retirement allowance constituted a share of the partnership's business income earned in Quebec, and the province validly exercised its taxing power.
