15 March 2006 External T.I. 2005-0124911E5 F - Prestation compensatoire française -- summary under Article 21

CRA found that a lump sum paid in two instalments paid as a “compensatory allowance” under French law by a French-resident ex-spouse of the Canadian-resident taxpayer was not includible in her income as a “support amount,” as defined in ITA s. 56.1(4). CRA found that this result was not altered by other-income Article (Art. 21) of the Canada-France Convention.