CRA noted that since s. 56(1)(v) requires an income inclusion for "compensation received under an employees’ or workers’ compensation law … of a province in respect of an injury,” compensation received by the estate of an injured worker pursuant to the Ontario Workplace Safety and Insurance Act was includible in its income (and deductible in computing its taxable income.) However, CRA noted:
[A]s compensation payments are not considered salary, wages, or other remuneration, they are not subject to the withholding of income tax, Canada Pension Plan contributions, and Employment Insurance premiums, irrespective of the recipient.