Principal Issues: Whether a taxable benefit would arise where an employer offers its employees a credit card with a discounted interest rate, relative to that ordinarily charged to non-employee cardholders?
Position: Where the credit card is a loan for purposes of subsection 80.4(1), any benefit so determined by virtue of this provision is included in income under subsection 6(9). Where the provisions of subsection 80.4(1) of the Act do not apply, the value of a benefit received by an employee in respect of a reduced interest rate may be assessed pursuant to paragraph 6(1)(a) of the Act.
Reasons: Revolving credit instruments such as credit cards constitute loans for purposes of subsection 15(2) and by extension, appear to be loans for purposes of subsection 80.4(1). It is always a question of fact, however, whether such loans have been received because of an office or employment. Where the provisions of subsection 80.4(1) do not have application, a benefit may be included under paragraph 6(1)(a).