The employer, which had been paying a portion of the premiums for a private health insurance program for its retirees, will be terminated for employee retiring on or after a specified date. As compensation for the termination, the employer will pay an allowance of a specified amount per month to each of its retirees who retired after the specified date. After finding that the allowances were not taxable under s. 5(1) or s. 6(3), CRA went on find that they were non-taxable as not being income from a source, stating:
We also refer you to … Fries … where the [Supreme] Court determined that an amount must come from one of the sources listed in the Act to be taxable.