What is the common law common law as it relates to damages for past income loss and loss of future earning capacity?

At common law, awards for past income loss and loss of future earning capacity were not subject to a deduction for tax; Gehrmann v. Lavoie, 1975 CanLII 166 (SCC), [1976] 2 S.C.R. 561. Legislation which is now in the form of ss. 95 and 98 of the Insurance (Vehicle) Act, altered the common law as it relates to those involved in motor vehicle collisions in British Columbia by providing that: 95 In this Part: ... ”net income loss”, in relation to a person who suffered loss of income as a result of an accident is, for any period, (a) if the person is a person referred to in section 2 (1) of the Income Tax Act, the gross income that the person lost in that period less the amount that would have been payable on that gross income for the following: (i) income tax under the Income Tax Act, as that Act read on December 31 of the calendar year before the calendar year in respect of which the net income loss is to be determined, calculated in accordance with the regulations and with reference to prescribed deductions and tax credits; (ii) income tax under the Income Tax Act (Canada) as that Act read on December 31 of the calendar year before the calendar year in respect of which the net income loss is to be determined, calculated in accordance with the regulations under, and with reference to deductions and tax credits prescribed under, this Act; (iii) premiums under the Employment Insurance Act (Canada), as that Act read on December 31 of the calendar year before the calendar year in respect of which the net income loss is to be determined, or ... 98 Despite any other enactment or rule of law but subject to this Part, a person who suffers a loss of income as a result of an accident or, if deceased, his or her personal representative, is entitled to recover from designated defendants, as damages for the income loss suffered after the accident and before the first day of trial of any action brought in relation to it, not more than the net income loss that the person suffered in that period as a result of the accident.