In explaining why the source deduction requirements (including graduated rates) under Reg. 102(1) would apply to Canada emergency response benefit (CERB) or Canada emergency student benefit (CESB) payments, the Directorate indicated:
- CESB/CERB payments can be provided over one or more 4-week periods and, thus, during pay periods as defined in Reg. 100(1).
- CRA considers the payments to be governmental financial assistance under s. 56(1)(r), so that they are deemed to be remuneration under para. (h) of the definition in Reg. 100(1), and so that the payer and payee are “employer” and “employee” under the Reg. 100(1) definitions.
- Although the payees would not be reporting for work, there would be a deemed establishment of the deemed employer under Reg. 100(4).