An insurance company, which pays commissions to a network of independent brokerage offices, awarded a door prize worth $1,500 to one of the employees of a brokerage office (as part of a contest addressed to the owners of the brokerage offices and their employees) and, as part of a promotion, organized draws pursuant to which it paid brokerage office owners and their employees prizes ranging from $500 to $2,500 in cash or in the form of a travel certificate. CRA stated:
[T]he door prize will be required to be included in computing the income of the employee who received it, pursuant to paragraph 6(1)(a). … With respect to prizes awarded to owners of brokerage offices and their employees under draws held over a period of several months … these prizes will be required to be included in the income of the owners and employees receiving them pursuant to subsection 9(1) and paragraph 6(1)(a) respectively.