2 October 1989 Ministerial Correspondence 58534 F - Earned Income

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

October 2, 1989

Dear Sirs:

Re:  Subparagraph 146(1)(c) of the Income Tax Act (the "Act")

This is in reply to your letter of August 17,1989 wherein you request a technical interpretation with respect to the definition of earned income for the purpose of paragraph 146(1)(c) of the Act.

We concur with your interpretation that amounts paid to an employee on a periodic basis from a sickness or accident insurance plan, a disability insurance plan, to which an employer has made a contribution, to the extent they are included in the employee's income by virtue of paragraph 6(1)(f) of the Act, represent "salary or wages" as that term is defined under subsection 248(1) of the Act. As a consequence thereof, these benefits are to be included in the computation of "earned income" for the purpose of paragraph 146(1)(c) of the Act.

The above comments are an expression of opinion only and are not binding on the Department. They are, however, our best interpretation of the relevant legislation as it applies generally and we trust that they are of assistance to you.

Yours truly,

for DirectorFinancial Industries DivisionRulings Directorate