4 June 2024 STEP Roundtable Q. 2, 2024-1003641C6 - Salary to Family Members -- summary under Subsection 248(28)

A corporation pays wages to an individual employee who was also a shareholder and a portion of the wages is subsequently determined to be unreasonable pursuant to s. 67. Although the overpayment would otherwise be income under s. 15(1), s. 248(28) would exclude the application of s. 15(1), so that there was no double taxation.

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