CRA rules on transactions whose stated purpose is to shift income from an individual’s professional practice to a family management company

An individual carrying on a professional practice will transfer various employees to a family corporation, with the corporation then charging him management fees, whose stated purposes is to reduce his income, and subject such income instead to (lower) corporate tax before distribution to a family trust which is one of the shareholders.

CRA ruled that the fees incurred by him would be currently deductible under s. 9 "subject to any application of sections 18, 20 and 67."  The summary contains the more helpful statement that:

Since the proposed structure does not contravene the laws and regulations governing the [professional] practice… in Quebec, the deduction of fees will not be denied as a current expense.

Neal Armstrong.  Summary of 2015 Ruling 2013-0513411R3 F under s. 18(1)(a) – income-producing purpose.