CRA presumes tailored benefits to be received qua shareholder

"When a person who is at the same time a shareholder and employee receives a benefit which is not offered to other employees, the CRA presumes that the person has benefited therefrom qua shareholder."

This position (on what is a question of fact) appears to be contrary to Pellizzari and Del Grande, and could be problematic where a key employee who requires special incentives or other accommodation also happens to be a shareholder.

Neal Armstrong.  Summary of 4 December 2013 T.I. 2012-0465891E5 F under s. 15(1).