When is an Indian's salary subject to tax?

We were also pressed with the decision in Williams v. Canada [1989] 1 C.N.L.R. 184, another tax case, where the taxability of unemployment insurance paid an Indian was under consideration. That case suggests the usual rule of situs of a debt is subject to the qualification that there may be evidence to indicate the situs is elsewhere. We can accept that qualification but see no connecting factor, as the term is there used, that brings the situs of the appellant's salary onto the reserve, except the fact that most of the work was performed on the reserve. We doubt that the place where the work is performed is relevant other than as some evidence which may assist in deciding the place for payment.