Bell v. Canada, 2000 DTC 6365, 2008 FCA 51 (FCA) -- summary under Section 87

One of the taxpayers was a status Indian residing close to a reserve, and the president and sole shareholder of a company employing 100 individuals (including 12 to 18 status Indians living on or near the reserve) in the company's business of commercial fishing. The Court affirmed the finding of the trial judge that the maintenance of a small office on the reserve that was used principally for the purpose of distributing cheques to the Indian employees of the company, and the fact that the earning of remuneration or profits from the company had a general economic benefit for the reserve, were not sufficient connections to the reserve to establish exemption. "Indians who acquire, hold and deal with property 'in the commercial mainstream' must do so on the same terms as their fellow citizens." (p. 6372).