16 September 2004 Internal T.I. 2004-0083421I7 F - Clause de non-concurrence - employé -- summary under Paragraph 6(3)(e)

The Directorate indicated that an amount received by an employee for entering into an agreement providing a non-compete and confidentiality covenant in the event of the individual’s employment was deemed to be employment income under s. 6(3)(e), stating in this regard that Fortino and Manrell “have no impact on the application of subsection 6(3).”