Unemployment insurance benefits received by an Indian were exempt from tax given that the employment by which he qualified for the benefits was clearly located on the reserve (the employer was located there, the work was performed there, the Indian resided there and was paid there). In rejecting a submission that the situs of the benefit should be determined on the basis of the situs of the debtor (the federal Crown), Gonthier J. stated (p. 6325):
"It is simply not apparent how the place where a debt may normally be enforced has any relevance to the question whether to tax the receipt of the payment of that debt would amount to the erosion of the entitlements of an Indian qua Indian on a reserve. The test for situs under the Indian Act must be constructed according to its purposes, not the purposes of the conflict of laws."