Before addressing the volunteer firefighter tax credit for “volunteer” firefighters working on a part-time basis for more than $17,000 per annum, CRA addressed whether amounts received by volunteers with modest remuneration might be exempt on general principles, stating that such payments:
are not very representative of the amount of work done or the quality of the services rendered.
They are not in themselves real motivators for volunteers to get involved and do not reflect the fair market value of services rendered. Therefore, those payments are not taxable.
However, the volunteer firefighters to which we were referred are not necessarily volunteers as defined above. If that had been the case, the $1,000 exemption and the volunteer firefighter tax credit would be meaningless as they only apply to taxable income.
Nowadays, there are almost no volunteer firefighters who can be qualified as volunteers in the true sense of the word, that is to say, unremunerated. In addition, the compensation paid to those workers in exchange for the work performed strongly suggests that they are employees.