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. … [W]here a particular class of member is determined, the deduction for a taxation year under subsection 137(2) of the Act by a credit union for bonus interest payments or payments pursuant to allocations in proportion to borrowing, as the case may be, requires such bonus interest payments or allocations in proportion to borrowing to be credited to all taxpayers who were members of that particular class in the year. ...

If the PF is an EBP, the amounts received therefrom would be taxable under s. 6(1)(g), subject to certain exceptions including that in 6(1)(g)(iii) regarding pension benefits received out of the plan that are attributable to services rendered by a person in a period throughout which the person was not resident in Canada – in which event, they would be fully taxable under s. 56(1)(a)(i) “even if the employee’s contributions to the pension plan were not deductible under the Act and even if the pension benefits are tax-free in whole or in part in a foreign jurisdiction.” ...

CRA further announced in 2020-0846751E5: In these extraordinary [COVID] circumstances, a HCSA that qualifies as a PHSP and which has unused credits expiring between March 15 and December 31, 2020, could temporarily permit the carry forward of those unused credits for a … period of up to six months [which] would generally be considered reasonable and would not, in and of itself, disqualify the HCSA from being a PHSP. ...

After noting that this definition can include an amount required to be paid under a net lease to a third party, such as an energy distributor, CRA indicated that “where a lease states only that a tenant is responsible for a certain cost … this would generally not constitute a qualifying rent expense.” ...

A reserve set up to provide for possible loan losses with no evidence of impairment would be a reserve for a contingency, and subject to the prohibition in paragraph 18(1)(e) …. ...

. … Generally, we would consider 60 days to be a reasonable period of time for the employer to terminate the arrangement and pay the amounts to the employee. ...

Accordingly, the amendments “apply only to dispositions that occur on or after … June 29, 2021.” ...

. … [U]nless the Dependent Beneficiary is the person legally entitled to the surplus income a trust will not qualify as an LBT as there is the possibility that a person other than the Dependent Beneficiary can receive or obtain, during the Dependent Beneficiary’s lifetime, the use of the income of the trust. ...

Thus, it is our view that the amount will not be included in the borrower’s income …. ...

CRA indicated that it had the discretion to grant a request to reduce the carrybacks so as to eliminate the GRIP reduction and associated Part III.1 tax (so that it might grant such request if it was satisfied that this was “a situation involving a bona fide error and not amounting to retroactive tax planning) provided that the loss years (2019 or 2020) were not statute-barred and that the request to reduce the carryback satisfied “the conditions … in subparagraphs 152(4)(b)(i) and 152(4.01)(b)(i) in respect of the [prior] Years.” ...