CRA effectively exempts a receipt to which s. 56(2) already has applied

CRA considers that where a real estate agent directs the real estate brokerage to pay a portion of a home-purchase commission to the purchaser, the amount of this "referral fee" will  be included in the agent's income under s. 56(2) irrespective of whether it is income to the purchaser.  Furthermore, as "it is the practice of [CRA] not to assess the same income twice," the brokerage would not be expected to issue a T4A to the purchaser.

This arguably is a "reverse Winter" situation.  That case (as limited by James) may indicate that if an amount is earned as income by the recipient, s. 56(2) does not impute income to a 3rd party who directed that benefit.  In any event, CRA presumably was mindful that most purchasers would treat the referral fee as an inducement that was not taxable under s. 12(1)(x).

Neal Armstrong.  Summary of 19 August 2013 T.I. 2013-0488011E5 ("Real Estate Referral Fees") under s. 56(2).