Income from fishing off-reserve was not taxable, given that fishing was an historical activity for the band in question, and that the fishing was carried out near the reserve. Hershfield J. found (at para. 130) that the income was "sufficiently connected in so many respects to the reserve as to be treated as property 'on the reserve.'"
The fact that the taxpayers' catches ultimately supplied a commercial fish reseller, "through" a reserve co-op, did not change the characterization of the property under s. 87.