1 R v. Savage [1983] 2 SCR 428

choral celtic, avant-garde jazz griot · 3:54

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Lyrics

[Verse 1]
In nineteen eighty-three a case would set the tone
Employee got a payment, question stands alone
Was passing workplace exams a benefit to declare?
The Supreme Court had to answer what makes income fair

[Chorus]
Savage says enrichment is the key
Economic advantage, what does it mean to me?
Not everything from employers counts as gain
Enrichment doctrine keeps the law contained
It must confer, it must enrich
That's the Savage switch

[Verse 2]
The facts were simple but the principle ran deep
A payment for exam success, was this his to keep?
Without the tax implications that would make it sting
The court looked past the surface to the underlying thing

[Chorus]
Savage says enrichment is the key
Economic advantage, what does it mean to me?
Not everything from employers counts as gain
Enrichment doctrine keeps the law contained
It must confer, it must enrich
That's the Savage switch

[Bridge]
Two S-C-R four-two-eight
The citation that would demonstrate
Not automatic, not assumed
Independent content consumed
Enrichment has its own demands
Beyond what flows from working hands

[Verse 3]
Before this case the line was blurred and undefined
Now economic advantage focuses the mind
The holding stands as bedrock law across the land
Taxable benefits need enrichment to expand

[Chorus]
Savage says enrichment is the key
Economic advantage, what does it mean to me?
Not everything from employers counts as gain
Enrichment doctrine keeps the law contained
It must confer, it must enrich
That's the Savage switch

[Outro]
Foundational and clear
The enrichment test is here
Savage set the standard high
Economic advantage, that's the why

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