The following excerpt is from Neuls (Bankrupts), Re; Touche Ross Limited v. First City Trust Company et al., 1985 CanLII 2367 (SK CA):
Further, it was argued that even if the principle of Higgins v. McNabb is applicable, the transfer of the bankrupts’ profit sharing plan to registered retirement savings plans was voluntary and therefore does not remain exempt. The transfer by the bankrupts was voluntary in the sense that they chose to purchase non-exempt property with the proceeds of the deferred profit sharing plan.
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