http://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/72949/index.do 
Schaub v. The Queen (July 4, 2014 – 2014 TCC 212 ) was a decision dealing with the taxation of pension payments to the taxpayer where his prior contributions had not been deductible to him:
[3] The Appellant immigrated to Canada from Switzerland in 1978 and became a Canadian citizen in 1981. When he lived in Switzerland, he made 190 mandatory monthly contributions to the Swiss pension plan called Alters und Hinterlassenenversicherung (“AHV”). While he was in Switzerland, his monthly contributions to the AHV were matched by his employer.
[4] It was his evidence that, in 1991, he started his own management consulting company in Vancouver and he decided to “diversify his long-term risk”. In 1993, he started to contribute to the AHV on a voluntary basis. I inferred from his evidence that he made both the employer and employee contributions to the AHV. Although it was very expensive, he made 191 voluntary monthly contributions to the AHV.
[5] The Appellant stated that he contacted the Canada Revenue Agency in 1993 and was told that he was not allowed to deduct the voluntary contributions he made to the AHV.
[6] The Appellant started to draw his AHV pension benefits in 2010.
[7] In 2012, the Appellant included the AHV benefit amounts in income and then claimed a deduction for the benefit amounts. He was initially assessed to include the amount of $17,781 of pension benefits in his income. The assessment was confirmed and the appellant has appealed that confirmation. In his notice of appeal, he raised the following issues:
a) Clear guidelines for the taxation of voluntary contributions to the AHV for Canadian citizens should be established.
b) There should be a clear statement whether the voluntary contributions to the AHV can be deducted from the taxable income of Canadian citizens.
c) He should receive a refund for the missed deductions from the taxable income for the years of voluntary contributions to the AHV.
Based on precedent the court concluded that the amounts were taxable:
[13] Ruparel v Canada, 2012 TCC 268 is a case very similar to the present appeal. There, the taxpayer’s spouse made voluntary contributions to the U.K. National Insurance plan. The voluntary contributions were not deductible from income when they were made. The taxpayer received the benefits under the plan but she claimed a deduction for the amounts equal to the voluntary contributions made by her spouse. In dismissing her appeal, Webb J., as he then was, stated that there were no provisions in the ITA which provided for the deduction of the capital elements of pension payments. This is true in the present situation. In Ruparel, the benefits received by the taxpayer were included in income under section 56 of the ITA.
[14] The convention between Canada and Switzerland for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital (the “Treaty”) does not prohibit the taxation of these pension benefits by Canada. Article 18 of the Treaty allows Switzerland to tax the pension benefits at 15% of the gross amount of the payment. The Appellant has stated that no taxes were charged in Switzerland. However, if they had been charged, the Appellant could have claimed a foreign tax credit in Canada.
[15] I have concluded that the amounts received by the Appellant from the AHV were superannuation or pension benefits and they had to be included in his income in accordance with subparagraph 56(1)(a)(i) of the ITA regardless that he was unable to deduct the contributions to the AHV when he made them. The appeal is dismissed.