After stating that
A loan is generally defined as delivery by one party, and receipt by another party, of a sum of money upon agreement, express or implied, to repay with or without interest.
CRA indicated that it considered 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. Accordingly, a “transitional payment” made to employees, as a result to switching the payroll system to an arrears system, would be currently taxable rather than treated as a loan subject to s. 80.4(1) even if the employees were required to repay any overpayment on termination of employment.