CRA found that bursaries paid to Quebec students under the Program québécois de prêts et bourses (the Quebec loans and bursaries program) by converting loans initially made to them into bursaries (following an ARQ verification of their income) that, thus, did not have to be repaid, were includible in income under s. 56(1)(n), subject to the exclusions under s. 56(3). CRA stated in this regard:
[S]tudents in Quebec "receive" a bursary even though they are only an intermediary between [the Ministry] and the financial institution and have no control over the bursary (the amount of the bursary being directly applied to the reduction of the loan granted to the student).