CRA was asked whether, in the determination of the reasonableness of income allocated to one of the partners of a partnership, CRA considers that the importance of the work accomplished by a partner in connection with partnership activities depends on the number of employees of the partnership (with a higher number reducing the relative value of the work performed by the partner). CRA stated (TaxInterpretations translation):
Although the CRA reserves the right to revise the share of income or loss of a partner in a partnership to be an amount that is reasonable under subsection 103(1.1), the number of employees of a partnership is not necessarily a relevant factor in the context of this determination. In particular, we believe that it is preferable to examine the contribution of each partner in the light of the contribution of the other partners in order to determine if the income or loss which is allocated to the partner is reasonable.