27 March 2007 External T.I. 2007-0226801E5 F - Orphelin(e)s de Duplessis -- summary under Paragraph 3(a)

Regarding $15,000 each paid to “Duplessis Orphans” (being inter alia orphans who had been designated by an institution as mentally retarded and who received no assistance under another program), CRA stated:

As stated in [IT-365R2, para. 2] all amounts received by a taxpayer or a dependant, as the case may be, that qualify as special or general damages for personal injury (for example, compensation for pain and suffering or for loss of amenities of life) will be excluded from income, regardless of the fact that the amount of such damages may have been determined with reference to the loss of earnings of the taxpayer in respect of whom the damages were awarded. Thus … the amounts paid under the Program will not be taxable to those who receive them.

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