Before addressing the treatment of a lump sum paid by a union to an active member on the member’s death, CRA discussed the treatment of amounts paid during a member’s lifetime, stating:
[A] taxpayer who receives, in a year, a dues refund that equals or exceeds the taxpayer’s annual dues paid to the union in that year cannot deduct their annual dues from employment income by virtue of paragraph 8(1)(i). In addition, the portion of the refund that exceeds the taxpayer’s annual dues must be added to the taxpayer’s income by virtue of paragraph 6(1)(j).