Canada v. Martin

canada, canadian, case law, court opinion, canlii, fca, 2026fca144, 2026 fca 144 (canlii), 2026, fca, 144, (canlii), a-14-25; a-13-25, 2026, taxation, non, resident employees, taxable income earned in canada, income tax act, s. 2(3), s. 115(1)(a)(i), whether allocation of duties in canada precedes applying exclusions, canadian, sourced compensation determined first, rca contributions excluded only after allocation, crown interpretation rejected, appeals dismissed, taxation, employment income allocation, retirement compensation arrangements, income tax act, s. 4(1)(b), s. 6(1)(a)(ii), whether act is applied to total compensation before allocating 40%, minister’s method would tax more than agreed canadian duties, canadian portion isolated on a place, by, place basis, taxpayers’ approach confirmed, appeals dismissed, pensions and social benefits, retirement compensation arrangements, employer contributions, income tax act, s. 248(1), part xi.3, whether rca contributions are compensation for duties performed in canada, actuarial reports and upc amendments supporting linkage to canadian duties, contributions treated as part of canadian, sourced compensation though excluded from income, characterisation upheld, appeals dismissed, statutory interpretation, income tax act, text, context and purpose, canada trustco mortgage co. v. canada, placer dome canada ltd. v. ontario (minister of finance), piekut v. canada (minister of national revenue), whether s. 115 interpretation permits taxing u.s., duty compensation, purpose to tax non, residents on canadian duties, correctness applied, appeals dismissed