Amendments to the Professional Code of Quebec resulted in several professional orders allowing their members to carry on their professional business through a corporation. CRA stated:
Where a professional order has adopted a by-law allowing its members to carry on their professional business through a corporation, we are generally of the view that a related management corporation may perform actual real management and administrative services for their professional business in relation to expenses directly related to their professional practice. The deduction of management fees is not, however, subject to special legislative rules. To be deductible, management fees must in accordance with paragraph 18(1)(a) have been incurred by a taxpayer for the purpose of earning income from a business or property, subject to section 67 which limits the deduction to an amount that is reasonable in the circumstances. In general, reasonable management fees correspond to the fair market value of the services rendered.