After disability payments to the taxpayer, under the policy taken out by the employer with an insurer, were suspended, then retroactively restored. However, the insurer discovered that, in the interim, the taxpayer had started receiving a pension under the Quebec Pension plan and also had been granted a retroactive pension by the employer – so that it claimed reimbursements of the disability payments it had made for the same periods. CRA stated:
[T]he word "arrangement" is broad enough to include a situation where a taxpayer must reimburse disability benefits to an insurer.
Thus, as long as all the conditions of paragraph 8(1)(n) are satisfied, we are of the view that the taxpayer may deduct the disability benefits reimbursed by the taxpayer to the insurer.