2004 Ruling 2004-0092931R3 - Deductibility Shareholder Manager Remuneration -- summary under Section 67

Ruling that a Canadian-controlled private corporation, which historically had paid large bonuses each year to its shareholder-managers and key employees to reduce its active business income to an amount approximating its share of the business limit, could pay deductible bonuses to such individuals out of recapture of depreciation realized on a sale of the majority of its business assets.