A loan made in 2011 by a corporation to its sole shareholder-employee to facilitate the repayment of a secured line of credit used to finance a home purchase in 2009 would be exempt from inclusion in the shareholder's income in the year the loan was made. After referring to IT-119R4, para. 18. CRA stated:
Whether the conditions set forth in paragraphs 15(2.4)(e) and (f) of the Act have been satisfied are [sic] always questions of fact to be determined on a case by case basis. Where a shareholder is the only employee of a corporation, the Canada Revenue Agency will generally consider a loan to be received by virtue of employment where a shareholder-employee can demonstrate that employees with similar duties and responsibilities with another employer of similar size, but who are not shareholders of that other employer-corporation, receive loans of similar amounts under similar conditions as that granted to the shareholder-employee.