There is a court case reported in the Tax Court of Canada, Stigen v. The Queen, regarding taxation imposed on interest income from investments. Stigen's argued that this income was personal property situated on reserve and should come under section 87(2) of the Indian Act and should be exempt from taxation as per section 81(1)(a) of the Income Tax Act, but the court denied the exemption.

This case is reported in the Canadian Native Law Reporter 2008 vol. 4 at pages 207 to 222 and indexed as Stigen v. Canada.