After noting that the Quebec Real Estate Brokerage Act (the “REBA”) required a real estate or mortgage broker carrying on brokerage activities through a controlled corporation to treat the remuneration therefor as belonging to the corporation, CRA stated:
[I]f the activities of a real estate or mortgage broker under the REBA … can be lawfully exercised through a corporation - which appears to be the case here - remuneration for the activities of the broker will be taxable in the hands of that corporation.