Question juridique clé
Whether child maintenance contributions are taxable when offset against a matrimonial property debt under an internal agreement.
Solution extraite
Yes. The contributions were realized as income when they arose and were usable for set-off; the internal agreement did not prevent taxation.
Motifs extraits
Set-off can operate only between existing claims. The child maintenance claims therefore constituted realized income for the custodial parent and increased her patrimony by reducing her liabilities.