Words and Phrases - "any kind whatever"
Pezzelato v. The Queen, 96 DTC 1285 (TCC)
The taxpayer's employer loaned him $250,000 to purchase a home on his move from Ingersoll, Ontario to Toronto because the taxpayer could not sell his Ingersoll home in time to finance the purchase of his Toronto home. In finding that the reimbursement by the taxpayer's employer of the interest paid by the taxpayer on the loan was a taxable benefit, Bowman TCJ. noted that the decisions of the Federal Court of Appeal in Phillips and Blanchard were irreconcilable with the earlier decisions in Splane and Ransom and that he should follow the Phillips and Blanchard cases because they were more recent decisions.
Bowman TCJ. also stated that the phrase "of any kind whatever" was not intended to add to the meaning of what constitute a benefit but to prevent the meaning of the word from being restricted by being interpreted ejusdem generis with board and lodging.
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|Tax Topics - General Concepts - Res Judicata||124|
|Tax Topics - Income Tax Act - Section 248 - Subsection 248(28)||67|