Lecturer's fees, director's fees and stock option benefits received by an individual member of a partnership and remitted to the partnership. Tax treatment to the individual and also to the other members of the partnership who received an allocation of such income.
Whether income received by a partner is that of the partner or of the partnership in any particular situation will depend on a finding of fact.
Per IT-377R, partnership can act as director. An individual can act on behalf of the partnership. However, the income earned will be that of the partnership. Also, in any other circumstances where the arrangement is entered into between the partnership and the payer for services to be performed, amounts received in respect of such services will be that of the partnership, irrespective of who performed the services.
Amounts received by an individual for his/her personal benefit for services performed by him/her and remitted to the partnership will be income of the individual under sections 5 to 8. This will occur where, for instance, the arrangement was made between the individual and the payer or the payer and the individual have an employer/employee relationship.
Fees received and included in the income of the individual partner and remitted to the partnership would not be included in the partnership's income. Instead, the amounts will be characterized as a contribution of capital to the partnership by the partner under subparagraph 53(1)(e)(iv).