CRA considers advances to employees to be currently taxable

CRA considers that an advance to an employee is current s. 5 income to him or her even if the advance is required to be repaid if the future services are not performed. This goes further than Merchant.

Neal Armstrong. Summaries of 26 April 2016 Internal T.I. 2015-062357 under s. 5(1) and s. 8(1)(n).