Regarding a location incentive program of the Quebec government for medical practitioners setting up in designated territories, and after indicating that such amounts were includible under s. 12(1)(x) where the physicians were self-employed, CRA stated:
[L]ocation incentives paid to medical practitioners under the programs put in place by the Quebec government to encourage medical practitioners to establish in remote areas are also taxable to medical practitioners who practise their profession exclusively as employees. They will thus be taxable as income from office and employment pursuant to paragraph 6(1)(a).