Subparagraph 56(1)(a)(i) provides that superannuation or pension benefits must generally be included in a taxpayer's income, "including, without limiting the generality of the foregoing," a number of items listed in ss. 56(1)(a)(i)(A)-(C.1). Hogan J. found that the general inclusion of "superannuation or pension benefits" at the beginning of s. 56(1)(a)(i) did not mean that clauses (A)-(C.1) were confined to only amounts that were superannuation or pension benefits - in the present case, clause (C.1) meant that the taxpayer was required to include in income an amount paid in redeeming a foreign retirement arrangement, regardless of whether that amount would normally be considered a superannuation or pension benefit (para. 35). The use of the word "includes" in a definition "enlarges the ordinary (or technical) meaning of the defined terms to include things that might normally be thought to fall outside their denotation" (Ruth Sullivan, Statutory Interpretation, 2d ed. (Toronto, Irwin Law, 2007), at p. 70).
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"including without limitation" is expansive
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