The appellant, a Haudenosaunee Iroquois Confederacy Treaty Indian, appealed reassessments of her 2013 to 2016 taxation years, arguing her employment income from an off-reserve hospital was exempt from tax under paragraph 87(1)(b) of the Indian Act.
The Tax Court of Canada applied the Williams test and found that the connecting factors, particularly the location and nature of her work, weighed in favour of taxation.
The appeals for 2013 to 2016 were dismissed, and appeals for other years were quashed.
