Ruparel v. The Queen, 2012 DTC 1218 [at at 3608], 2012 TCC 268 (Informal Procedure) -- summary under Superannuation or Pension Benefit

The taxpayer and her husband were UK residents. When they moved to Canada, the taxpayer's husband continued to make voluntary payments to his UK National Insurance plan in order to qualify for his pension under that plan. Webb J. found that all amounts received under the plan should be included in the taxpayer's income, even though there was no corresponding income deduction, and hence double taxation, on the voluntary payments made in Canada. The pension payments were required to be included in income under s. 56(1)(a)(i), and there is no mechanism in the Act that would allow "return of voluntary contributions" to be excluded from income.