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In accordance with ITA 5 6 . 4 ( 2 ) , any payments made to a taxpayer for agreeing to a restrictive covenant must

In accordance with ITA56.4(2), any payments made to a taxpayer for agreeing to a restrictive covenant must be included in income as "other income" under subdivision"d". Which of the following is NOT one of the exceptions to this general rule listed under ITA56.4(3)?
A. Where a joint election is filed, the payment can be classified as a capital gain that is eligible for the lifetime capital gains deduction.
B. Where a joint election is filed, the payment can be classified as proceeds of disposition of a Class 14.1 asset by the taxpayer.
C. Where the payment relates to past employment services with the payor, the income can be classified as employment income and subject to tax when received(on a cash basis).
D. Where a restrictive covenant is sold along with shares in a corporation that carries on a business, the payment can be added to the proceeds of disposition of the shares if a joint election is filed.

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