"If there were sufficiently strong, concrete and discernable connections between the property and a Reserve, the exemption would be available to the Indian." (See para. 38 citing the SCC cases Bastien Estate and Dube. Busines income will be exempt if the taxpayer lived on a reserve or the business took place on the reserve. (Para. 54)
Here, three of the four homes Mr. Pilfold had were off-reserve. And Justice Miller found that the business planning, decision-making, fishing and sales were mostly off-reserve; so the income wasn't exempt.
Pilfold Estate, 2013 TCC