An employer received an additional budget envelope from a government Ministry, identified as a lump-sum performance bonus, so that the Ministry had the means to promote and recognize its management staff. The Ministry provided that an employee could request that the lump sum performance bonus be used for skills development. In finding that the bonuses were taxable under s. 5(1) irrespective of any such application thereof, CRA stated:
[W[here an employee renounces an amount to which the employee is or will be entitled, such as a bonus paid or to be paid in the course of the employee’s employment, by converting it into a non-taxable tuition payment or reimbursement, the employee must include the amount of remuneration so converted in computing his income for the year in which the conversion takes place. The fact that the funds for the bonus come from a Ministry of the government does not affect the nature of the payment made to employees.