Principal Issues: Was an Indian's employment income taxable?
Position: Question of Fact
General information provided. Very few details were provided with which to make a determination. We would have to assume that the individual is a status Indian since there is no confirmation of this fact. The memo indicates that the taxpayer does not live on reserve, that her employer was not resident on reserve and that approximately 30% of her duties were performed on reserve. The Proration Rule appears to apply to exempt 30% of her income.