Tsiaprailis v. Canada, 2005 DTC 5119, 2005 SCC 8, [2005] 1 SCR 113 -- summary under Section 68

By services, 10 February, 2022

After referring (at para. 51) to the “need to compartmentalize global payments into their constituent portions to determine which are taxable,” Charron J found that the portion of a lump sum damages payment that had been agreed to be compensation for arrears of disability payments was taxable under the surrogatum principle.

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general authority to allocate global amounts without reference to s. 68
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