Lorenzen v. The Queen, 81 DTC 5251, [1981] CTC 377 (FCTD) -- summary under Retiring Allowance

The taxpayer arranged for the transfer of the assets of one company to a second company that was also controlled by him. Although the taxpayer was paid $20,000 in respect of relinquishing the presidency of the first company, it could not be said that he received this amount in respect of "loss" of office because he engineered the termination of office himself, and he suffered no loss because the business was carried on by him as before. Similarly, there was no "retirement" because he remained a director of the first company and he continued with the same business at the second company. [C.R.: S.56(1)(a)(ii)]