13 June 2012 Internal T.I. 2012-0448961I7 F - Paiements en trop faits par un employeur -- summary under Subsection 80.4(1)

An employee was on extended sick leave but nonetheless received remuneration from the payroll service, which was not informed of the leave. On the employee's return to employment a number of years later, the error was discovered, and it was agreed that the overpayments would be repaid over a period that straddled two calendar years through deduction from the employee's post-return remuneration. CRA stated (TaxInterpretations translation):

[T]he fact that the employee reimburses the overpayments gradually does not constitute a non-interest bearing loan. Accordingly, the employer should not calculate a taxable benefit for imputed interest.

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