CRA comments on “qua employee” status where the individual also acquires 3% of the shares
A general response to a question as to whether a new CEO of a CCPC was receiving a housing loan qua employee (so that s. 15(2.4)(b) could apply) given that he also was acquiring 3% of the corporation’s shares may imply that CRA was not startled by the proposition that this was the case, stating:
[G]enerally … “benefits” are received qua shareholder where that person can significantly influence the corporation’s business policy. However, this might not be the case where the individual is only a minority shareholder of the corporation and does not otherwise have significant influence over the corporation.
Neal Armstrong. Summary of 14 June 2019 External T.I. 2019-0808411E5 under s. 15(2.4)(e).