Regarding requested clarification of the position in Income Tax Technical News No. 30 that all pre-judgment interest, which is “explicitly identified” as interest in a court order or out-of-court settlement, will be taxed as interest income, CRA stated:
[T]he tax treatment of pre-judgment interest explicitly identified as described in your request varies according to the specific terms and conditions of each judgment or out-of-court settlement. That determination is essentially a question of fact.