Gill v. The Queen, 2012 DTC 1261 [at at 3764], 2012 TCC 302 -- summary under Subparagraph 56(1)(a)(i)

The taxpayer received $75,175 as a redemption of his deceased US-resident sister's individual retirement income account. Hogan J. found that this amount was required to to be included in the taxpayer's income under s. 56(1)(a)(i)(C.1). The self-represented taxpayer argued that the words "without limiting the generality of the foregoing" meant that the items listed in clauses (A)-(C.1) should be taxed only if they constitute superannuation or pension benefits as those terms are generally understood. Hogan J. rejected this argument because, inter alia, "interpreting clause (C.1) as including lump-sum payments from IRAs does not restrict the ambit of subparagraph 56(1)(a)(i); rather, it expands it" (para. 36).