Blott – Tax Court of Canada finds that giving a spouse access to a joint account was not payment to her

A securities dealer employee claimed a deduction for salary to his wife of $12,000 per annum for her administrative support. In addition to finding that this claim was non-deductible on more usual grounds (e.g., a negative T2200), C Miller J found that there had been no expenditure, stating:

… There are no cheques to Ms. Thériault. Mr. Blott’s income went into the joint account and Ms. Thériault could simply access it. Is there any amount paid to Ms. Thériault in such circumstances? I conclude there is not. … I do not see how anything has been paid or expended to Ms. Thériault. She has received nothing more than what she already had.

Neal Armstrong. Summaries of Blott v. The Queen, 2018 TCC 1 under General Concepts – Payment and Receipt and s. 8(1)(i)(ii).