CRA considers that writing-off a statute-barred debt of an employee triggers a s. 6(15) benefit
CRA considers that whenever a debt owing by an employee is extinguished because of an employer action, s. 6(15) deems the forgiven amount to be an employment benefit. Respecting the situation where an employee debt becomes statute-barred (which presumably is not subject to the deemed settlement under s. 80.01(9) because the debt is not a commercial debt obligation), and the employer then writes it off because it is thus no longer legally collectible, CRA considers this writing-off to be sufficient to trigger s. 6(15). Cf. Diversified Holding: “for a debt to be settled or extinguished…there must be a legally binding termination in form.”
Neal Armstrong. Summary of 12 October 2016 Internal T.I. 2016-0637781I7 under s. 6(15).