Kerr v. Canada (Superintendent of Income Tax), [1942] SCR 435 -- summary under Subsection 92(2)

The taxpayer submitted that the tax imposed by the Income Tax Act (Alberta) was a tax on income rather than a tax on persons, so that the Province was precluded from imposing tax on the taxpayer's foreign source income. Kerwin J. stated (at p. 444) that he was of the opinion "that the Act, taken as a whole, imposes a tax on a person such as the appellant who was found in the province with respect to his income, including that derived from sources outside the province".