Roszko – Tax Court of Canada finds that “interest” received under a Ponzi scheme was non-taxable

Purported interest payments which the taxpayer received under promissory notes issued to him in a Ponzi scheme were not taxable.  C Miller J valiantly distinguished Johnson on the basis of "a distinction between earning income based on a fraudulent act or illegal activity versus a finding that the contract itself is a fraud," stating that in the latter situation there is no source of income.

Neal Armstrong.  Summary of Roszko v. The Queen, 2014 TCC 59 under s. 3 – reasonable expectation of profit/business activity.