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The Tax Court allowed Ms. Tchiakoua’s appeal, holding that a $5,423 Quebec student loan remission was not taxable under paragraph 56(1)(n).
The court found on the facts that the $1,200 scholarship was paid to the employee as a resulting trust for her daughter; the employee did not receive or enjoy the benefit and therefore the amount was not taxable to the employee under paragraph 6(1)(a) and instead qualified as scholarship income of the daughter under paragraph 56(1)(n).
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