Large v. The Queen, 2006 DTC 3558, 2006 TCC 509, briefly aff'd 2008 DTC 6015, 2007 FCA 360 -- summary under Section 87

The taxpayer, a status Indian who resided both on and off a reserve, transferred investments to a corporation resident on the reserve and controlled by her non-Indian husband and his children from a previous marriage in consideration for an interest-bearing promissory note of the corporation. The interest on the note was not exempt given that its income was derived from guaranteed investment securities and publicly traded securities whose income, in turn, was largely generated off-reserve.