March 10, 1993
| Ottawa District Office | Business and General Division |
| P. Lesperance | Client Assistance |
| Dir. | Murray Brake |
| 2nd Floor | (613) 952-0243 |
XXXXXXXXXX
This is in reply to your round trip memorandum of February 26, 1993, wherein you asked for our opinion relating to the taxability of XXXXXXXXXX XXXXXXXXXX is a Status Indian living on a reserve. His income was from employment off the reserve. Also, the employer is not located on the reserve.
Based on the Glenn Williams case, it is necessary to consider the factors which could connect the employment income to a location on or off a reserve.
In the situation at hand, it appears the only factor connecting XXXXXXXXXX employment income to a reserve is his residence. There is no indication of any other factors which could arguably connect the employment income to a location on a reserve. Hence, there is no doubt thatXXXXXXXXXX is taxable on his employment income earned off the reserve.
E. Wheeler for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch