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CCRA indicated that the question of whether the payment of the “deferred salary” was of income turned on whether it was “similar to one of the items that must be included in computing a taxpayer's income for the purposes of the … Act”. ...

However … article 72 of the Decree and the absence of an employment contract or subordination relationship seem to indicate that the relationship between the creditor and the debtor of the “deferred salary” does not constitute an employer-employee relationship. ...

., a group sickness or accident insurance plan (“GSAIP”), a private health services plan (“PHSP”), or a group term life insurance policy (“GTLIP”)) allows for the provision of benefit coverage to such individuals – although a GTLIP may only provide benefit coverage to current and former (including retired) employees. ...

Consequently, the requirement in paragraph 107.4(1)(i) would be satisfied …. ...

Consequently … no limited partnership loss can be deducted by Opco in computing the ASPA so as to reduce the amount to be added to its income under subsection 34.2(1). ...

CRA noted that the FMV of the property in the RRSP normally would have been included in the deceased annuitant’s income under s. 146(8.8) but here, there was no inclusion of such amount in the final return because the executor was unaware of the RRSP – and that return now was statute-barred. ...

. … [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.” ...