The trustees of a REIT (who in that regard were not acting in the course of a business) received fees from the REIT equaling $20,000 per year, plus $1,000 for each meeting attended in person (or $500 if attended by telephone) plus reimbursements for out-of-pocket expenses incurred in the performance of their duties as trustees. CRA concluded that such fees were from an “office,” and that:
[T]he REIT would therefore be required to withhold tax from the fees paid to its Trustees by virtue of paragraph 153(1)(a) and to issue a T4 information slip to each of them in that regard.