By operation of 96(1.1)(b), which applies notwithstanding any other provision of the Act, "allowances" received by a retired partner from his former firm (KPMG), which were treated under the partnership agreement as an allocation out of profits, had to be treated as partnership income rather than pension income. Lamarre J. further indicated (at para. 28) that, if the income were treated as pension income, that would be in addition to its treatment as partnership income - a double-counting of income, prohibited by s. 248(28).
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treatment of an allocation of partnership profits pursuant to s. 96(1.1)(b) also as pension income would be contrary to s. 248(28)
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337471
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