Does a plaintiff have to declare tips as income on her tax return?

British Columbia, Canada

The following excerpt is from Sohal v. Singh, 2017 BCSC 734 (CanLII):

The plaintiff did not declare any tips as income on her tax returns but that does not disentitle her from including tips in her past income loss claim, provided the court is satisfied that the plaintiff in fact would have earned tips but for the accident: Wepruk v. McGarva and Butt, 2006 BCCA 107 at paras. 18-19.

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