In order to encourage members to participate in union activities on their day off, the union compensates them during their attendance at union councils or conventions where matters such as working conditions, training, pressure tactics if necessary, and the general administration of the union are discussed. CRA stated:
[W]here the member who attended the conventions is not employed by the union and the member does not carry on a business in the course of which the member receives those amounts, the amounts the member receives as compensation for attending union councils or conventions on their days off would not be derived from a source of income and would not be taxable.