The value of the s. 15(1) benefit arising from the provision of property (e.g., a yacht or luxurious residence) to a shareholder may be computed by multiplying a normal yield by the higher of the cost of the property and its fair market value ("FMV"). If the prescribed rate in Reg. 4301(a)(i) cannot be used, how should the normal yield be determined? CRA responded:
When the CRA calculates a benefit conferred on a shareholder by multiplying the normal yield rate by the higher of the cost of the property and its FMV, the goal is to measure the benefit to the shareholder taking into account a reasonable return on the value or the cost of the property. …
[I]n situations where the Prescribed Rate is not representative of the normal yield rate, the Prescribed Rate will not be the rate which is used in calculating the value of the benefit to the shareholder.
…The CRA will examine all the relevant facts in establishing the normal yield rate… .