90 C.P.T.J. - Q.14

Even prior to the replacement in s. 12(1)(x)(iv) of "expense" by "outlay or expense", s. 12(1)(x)(iv) was not limited to reimbursements of deductible costs, as the provision referred to "expenses" rather than to "expenses deductible in computing the taxpayer's income for tax purposes".

An election pursuant to s. 12(2.2) will eliminate any income inclusion assuming that the election is filed on time and the reimbursement relates to outlays or expenses incurred within the time frame set out in s. 12(2.2).