By Cris Best ( October 20, 2026, 2:25 PM EDT) -- In the decision of Canada v. Martin, 2026 FCA 144, the Federal Court of Appeal was tasked with determining the scope of taxable Canadian source income earned by two professional baseball players employed by the Toronto Blue Jays: Russell Martin and Josh Donaldson. The Canada Revenue Agency (CRA) reassessed the players’ taxable income to increase the tax owing based on the differing treatment of a retirement compensation arrangement (RCA). The CRA’s position was rejected by the Tax Court of Canada in Martin v. Canada, 2024 TCC 153, which was appealed to the Federal Court of Appeal....