2006, M O’Brien, abstract of "Surrogatum, Source, and Tsiaprailis: Is There a Principled Basis for the Tax Treatment of […]", in Canadian Tax Journal
In that decision, the surrogatum principle was, for the first time, clearly extended beyond payments that replace business or property income or proceeds of disposition of a capital property used in a commercial context.
2006, Preparing Your Income Tax Returns, page 135
The Supreme Court introduced reliance on the "surrogatum principle", holding that replacement payments take on the character of the amounts they are […]
[a mention, due to quotes]]
2008, B ALARIE, DG DUFF, The Legacy of UK Tax Concepts in Canadian Income Tax Law, papers.ssrn.com
As this application of the so-called surrogatum principle appears to depart from cases involving payments in lieu of notice […]