CRA indicates that the salary of a status Indian from his corporation may be exempted based on the relative sourcing of its income on and off reserve

A physician and status Indian who lives off the reserve and is the sole shareholder of a corporation that is managed from an office on the reserve spends 70% of his time as employee on the reserve (mostly on patient care) and 30% off the reserve performing hospital duties. CRA indicated that although this was a question of fact, it might be considered that since 70% of the corporation's business income was located on a reserve, 70% of the physician’s salary from his corporation should be exempted.

Neal Armstrong. Summary of 4 April 2024 External T.I. 2023-0996201E5 F under Indian Act - s. 87.