What elements must be present for an amount to constitute ordinary income under s 6-5 of ITAA 1997? The benefit must be cash or cash convertible; a real gain, it must have a nexus with an income earning activity; benefit must not be in the nature of capital. Benefit is cash or cash convertible paid in a lump sum for property. It meets all of the 4 tests set out in s 6-5 of ITAA 1997. The benefit was intended to be income