Per curiam:
1 We are all of the view that this appeal cannot succeed. As the learned Tax Court Judge characterized it in his reasons (A.B. p. 512), the payment in issue in this appeal was “made pursuant to the appellant's overall, on-going compensation package for services rendered” in Canada as an employee of General Motors of Canada Limited. As such it was income of the Appellant for the taxation year 1990 within the meaning of subsection 5(1) of the Income Tax Act, it being salary, wages, or other renumeration from her employment. On this basis alone, the learned Tax Court Judge was right in dismissing the Appellant's appeal from the Minister's assessment for the 1990 taxation year.
2 Even if the taxability of the amount in issue in this appeal were governed by section 6 of the Act, as if there had been a real reimbursement for an expense actually made, then the line of jurisprudence such as Ransom v. Minister of National Revenue, [1967] C.T.C. 346, 67 D.T.C. 5235 (Can. Ex. Ct.)and the cases following it, upon which the appellant relies, would not be applicable. The reason is that each of those cases dealt with losses or payments made by the employee in order to perform the services and not as here, an expense made by him as a consequence of the receipt of the renumeration.
3 The appeal will therefore be dismissed with costs.
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