7 July 2009 External T.I. 2008-0267941E5 F - Pompiers volontaires -- summary under Subsection 5(1)

Before going on to infer a broader meaning of “volunteer” in the context of s. 81(4), CRA indicated that normally, a “volunteer” (i.e., someone who would not receive any benefits from the municipality as employment or business income) would references 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”).