Volunteer directors who attend four meetings a year of the board of directors of a not-for-profit organization do not receive any attendance fees, but receive reimbursement for automobile expenses incurred in attending meetings and, where they live more than 500 kilometres away, are reimbursed for their airfare. They also receive allowances for meals consumed while attending the meetings and, if accompanied by their spouses, the same amounts are paid as spousal meal allowances.
After stating that although “a director is generally considered to hold office, this is not the case for a director who works for a company solely on a voluntary basis,” which references the situation where “individuals who work on a volunteer basis receive no remuneration or at most minimal remuneration for services rendered on a volunteer basis” – with remuneration considered minimal where the remuneration paid to the individual is “significantly less than that which would have been paid to an employee or self-employed person rendering similar services,” so that “it is unlikely that minimal remuneration is sufficient to secure the volunteer's services.” CRA stated that here:
[I]f the facts as a whole show that the individuals perform their duties as directors on a volunteer basis and not in the course of an office or employment or as self-employed persons, in our view, reimbursement of automobile expenses, reimbursement of airfare and meal allowances for attending board meetings (including allowances paid to cover meals for their spouses while travelling) would not be considered employment or business income if they are the only amounts received by them.