Respecting the situation where an independent contractor incurred home office or automobile expense and another person (who might be a spouse) paid such expenses, CRA stated:
Where business expenses have been paid by someone other than the taxpayer carrying on the business, the amounts so paid could, depending on the circumstances, be included in the income of the taxpayer's business or give rise to the application of section 80.
The question of whether those amounts should be included in the income from the taxpayer's business is one of facts that can only be resolved after an analysis of all relevant facts specific to each situation.
The jurisprudence (Ikea Limited v. The Queen, [1998] 1 SCR 196 and Canderel Ltd. v. The Queen, [1998] 1 SCR 147) has established principles for determining whether an amount qualifies as income for the purposes of the Income Tax Act for a taxation year. The principles developed by the jurisprudence will help a taxpayer to determine whether the amounts paid by another person must be included in the taxpayer’s income under section 9.