A union wishes to return to its members the amounts it has accumulated and over-collected from them. After noting the potential for inclusion under s. 6(1)(j) of certain union-dues reimbursements, CRA stated:
[I]n certain situations a taxpayer may receive amounts from a union that are not a reimbursement of union dues. In such cases, and based on … Fries … those amounts will not be required to be included in the taxpayer's income since they do not represent income from a source in Canada. Similarly, a fund generated over the years for legitimate union purposes that is no longer required as a result of the disposition of the union's operations and that is distributed to union members will not be required to be included in the income of the union members.