2012-0472211I7 concerned a Canadian company (the “Taxpayer”) that provided free annual trips to southern resorts to high-performing brokers and sales agents of its products or services, who could be performing the services as individual proprietorships, or through personal corporations. The trips included morning briefings on the Taxpayer’s products.and services. CRA clarified that:
In determining the taxpayer's profit for a taxation year for the purposes of section 9, the Canada Revenue Agency generally expects, in a situation similar to that described, that the taxpayer will include the value of the business part and the personal part of the trip.