In Chalmers v Russell, the Court held that payments for banked sick time are tax exempt in a damages award for loss of income.
 I accept Ms. Chalmers’ evidence that following the first accident, she was so sore and painful that she felt it necessary to take time off work prior to the birth of her child in order to expedite her recovery. I am mindful that she did not obtain any medical evidence in support of her decision to take time from work. Regardless, given her advanced state of pregnancy, the trauma of the accident and the pain she was in after the first accident, I consider her decision not to return to work to be reasonable and due to her injuries. The cost to reimburse the sick bank during this time period is $342.45 per day, totalling $3,766.95.
 As noted in Bjarnason v. Parks, 2009 BCSC 48, depletion of a sick bank is a compensable loss: at para. 56. However, it is not an income loss so there should be no deduction for income tax in accordance with ss. 95 and 98 of the Insurance (Vehicle) Act, R.S.B.C. 1996, c. 231: Bjarnason at para. 66.