Source concept of income

1

• Source concept of income
• Nexus

2
What is income?

• Haig-Simons
• Income Consumption Change in wealth
• Example increase in share value vs dividends

3
Imputed Income

• How does it fit with Haig-Simons?
• How does it fit with ITA?
• Example Own vs rent a home

4
Tree and fruit
5
Source

• Bellingham (1996, FCA)
• Schwartz (1996, SCC)
• Fortino (1997, TCC)

6
Indicia from Cranswick

• No enforceable claim
• No organized effort
• Not sought after
• Not expected
• Not likely to recur
• Not a customary source
• Not in consideration

7
Nexus

• Minet (1998, FCA)
• Buckman (1991, TCC)
• Grant (1967)