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After referring to Guide T4130, p. 24 and stating that the s. 7(1)(a) benefit is computed on the basis of the shares' fair market value "at the moment of their acquisition," CRA stated (TaxInterpretations translation): … [I]n the context of a short sale, the CRA is generally of the view that an employee has acquired the shares of the employer at the moment the employer transfers the shares to the employee and they are paid for. ...

. … The legatee by particular title must include it in computing income under subsection 104(13). ...

. … [However] it is the practice of the Canada Revenue Agency not to assess the same income twice. ...

CRA went on to state: … [A] failure to report income as required, and false statements or omissions, in respect of prescribed reporting requirements may result in substantial penalties under section 162 or 163. ...

CRA went on to state: … [A] failure to report income as required, and false statements or omissions, in respect of prescribed reporting requirements may result in substantial penalties under section 162 or 163. ...

. … Where counselling services are part of a program provided by a personal trainer or nutritionist, it is our view that the value of any benefit derived from such services would be difficult to separate from the value of any other benefits received or enjoyed under the program. ...

As a result … provided the amounts withdrawn are from an RRSP where only the annuitant paid premiums, the withdrawals would be included in the computation of the annuitant's income under subsection 146(8). ...

. … As such, the amount of LTD Plan payments that would be taxable as income earned by a non-resident employee would be determined in accordance with subsection 115(2) and withholdings under Part XIII would not be applicable… [and] the LTD Plan payments would be subject to withholding under paragraph 153(1)(a)…. ...

. … As such, the amount of LTD Plan payments that would be taxable as income earned by a non-resident employee would be determined in accordance with subsection 115(2) and withholdings under Part XIII would not be applicable… [and] the LTD Plan payments would be subject to withholding under paragraph 153(1)(a)…. ...

Finally, where a life insurance policy was assigned as security to the lender prior to March 21, 2013 and it is then replaced with a new life insurance policy after that date … this fact, in itself, will not jeopardize the grandfathered status…. ...