Principal Issues: Whether a remedial payment made by an insurer to a member’s defined contribution account of a registered pension plan is a contribution for purposes of paragraph 147.2(1)(a) and taxable to the member under section 5 or 6?
Position: Question of fact.
Reasons: A remedial payment made to a registered pension plan in respect of an actionable loss suffered by the plan does not constitute a contribution or gift to the plan and will not result in an income inclusion to the member.