The appellants, registered Indians who resided and worked in Winnipeg, appealed reassessments of their 2012 and 2013 taxation years.
They claimed their employment income was exempt from tax under section 87 of the Indian Act because their employer, a corporation owned by Tribal Councils, was resident on a reserve and provided benefits to First Nations.
Applying the connecting factors test, the court weighed the residence of the employer against the fact that the appellants resided, worked, and were paid in Winnipeg.
The court concluded that the location of the employment duties in Winnipeg was the predominant connecting factor, outweighing the employer's connection to a reserve.
The appeals were dismissed.
