Her Majesty the Queen in Right of the Province of British Columbia v. Gilbertson
United States Court of Appeals for the Ninth Circuit
597 F.2d 1161 (1979)
Facts
The Canadian Province of British Columbia (British Columbia) (plaintiff) imposed a tax on Oregon citizens (the Oregon citizens) (defendants) for income received from logging work performed in British Columbia. British Columbia served the Oregon citizens with a notice of intent to enforce the income tax and filed a certificate of tax assessment in a Canadian court. The certificate was the functional equivalent of a judgment against the Oregon citizens for the taxes allegedly owed to British Columbia. British Columbia then filed suit against the Oregon citizens in an Oregon court, seeking to enforce the Canadian judgment. The court dismissed the action on the ground that, under the revenue rule, the court did not recognize the revenue laws of another country. British Columbia appealed.
Rule of Law
Issue
Holding and Reasoning (Anderson, J.)
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