The appellant, an Indian residing on a reserve, received regular and enhanced unemployment insurance benefits based on qualifying employment located on the reserve.
The Minister of National Revenue assessed these benefits as taxable income.
The Supreme Court of Canada held that the situs of the benefits should be determined by evaluating various connecting factors in light of the purpose of the Indian Act tax exemption.
Because the qualifying employment was located on the reserve, the benefits were also situated on the reserve and thus exempt from taxation under section 87 of the Indian Act.
