Before finding that the allowance was non-taxable to the recipients as not being income from a source, CRA indicated that they were not taxable under s. 5(1) and also were not taxable under s. 6(3), stating:
[T]he payments do not meet the criteria of subsection 6(3), which deals with amounts paid on account of or in full or partial consideration or partial consideration of an obligation between an employer and employee. Rather, the compensation received in this case relates to the loss of a plan benefit.