After noting that although normally, a “volunteer” (i.e., someone who would not receive any benefits from the municipality as employment or business income) would reference the situation where any consideration paid “does not adequately reflect the amount of work performed nor the quality of the services provided (whereas “where the amount of remuneration paid … is sufficient to influence their involvement or participation, it is very likely that the remuneration is taxable as employment income or income from a business”), CRA went on to say that, in the context of s. 81(4):
The volunteer firefighters we are referring to are not necessarily volunteers in the sense established above. Had this been the case, the $1,000 exemption would lose all of its meaning as it only applies to taxable income. …
… [P]rovincial laws … such as legislation on labour standards or on occupational health and safety … [define] "volunteer firefighters" … . [W]e should base our understanding on who is a volunteer firefighter by reading the definitions established by such legislation and related publications. This approach allows some light to be shed on the meanings provincial government authorities accord to the expression as well as municipal or other public administrations.
… [M]unicipalities and other public authorities are better able to determine the status of their employees. Paragraph 81(4)(b) states that this responsibility clearly falls on the shoulders of the municipality or public authority. … [On] an audit …[it] could be asked to … justif[y] its decision to grant … the exemption … .