•Section 61 does not define the domestic sources of a Citizen’s taxable income at all.As far
as citizens are concerned, Section 61 only defines the Canadian
sources of taxable gross income under the Canadian Tax Treaty.•Which agrees with
everything else in the law that we have seen regarding subtitle A income tax being a foreign
tax in the form of
a tariff, exactlyas it was identified
by the Supreme Court in
the BrushaberOpinion
in 1916!