The U.S. government obtained a judgment from a U.S. court for U.S. income taxes owing by the respondent, who now was resident in B.C. In affirming the findings below that this judgment was unenforceable in the B.C. Supreme Court, Cartwright J stated (at pp. 369, 371, SCR):
[T]he appellant [did not] question the well-established general rule...that a foreign state is precluded from suing in this country for taxes due under the law of the foreign state... .
[A] foreign State cannot escape the application of this rule, which is one of public policy, by taking a judgment in its own courts and bringing suit here on that judgment. The claim asserted remains a claim for taxes.