2012-0472211I7 concerned a Canadian company which 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 had a business portion including morning briefings on the company’s products and services.
CRA indicated that the company providing the trips should issue T4A slips to the individual proprietor, or to the individual receiving the trip as a benefit qua employee of the individual’s personal corporation – whereas no T4A slip is required if the trip was received as a benefit qua shareholder of the personal corporation (a distinction which in practice would be difficult or impossible for the trip provider to apply). If the trip was received qua individual proprietor, the full value of the trip was to be recorded on the T4A, whereas if the trip was received qua employee, only the value of the benefit was to be recorded.