The next of the three key cases and the most important for our purposes, is United States of America v. Harden 1963 CanLII 42 (SCC), [1963] S.C.R. 366. In this case the U.S. government sued in British Columbia upon a judgment obtained in California and based on unpaid taxes. U.S.A. contended that the long established rule against a sovereign power not enforcing the revenue laws of another state had no application for two reasons: 1. The action was based on a judgment - not on a tax claim and 2. The judgment sued on was the result of an agreed amount which was less than the actual tax claim and therefore the B.C. action was based on contract and not the tax claim.
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