Principal Issues: (1) Will the CRA be providing similar administrative relief to self-employed income that was applied to employment income as a result of the COVID-19 restrictions? (2) Is self-employed income earned by a physician from providing medical services virtually eligible for the tax exemption under Section 87 of the Indian Act.
Position: (1) No (2) It depends, based on a connecting factors test.
Reasons: (1) There is no standard test that can be used to determine if business income is situated on a reserve, therefore similar guidance would not be feasible. (2)A connecting factors analysis would be required to determine whether the income is situated on a reserve.
