Malamute Contracting Inc. v. The King (2025 TCC 47) reported on today in “News of Note at Tax Interpretation” is VERY instructive for anyone dealing with smaller, self-bookkeeping clients.
TL;DR version: corp booked payments to shareholders, some marked as “salary” but others not. CRA on audit applied withholdings to all “salary” payments that were similar. TCC found against CRA…just “payments to shareholders” and allowed treatment as s/loan recharacterized later as dividends.
Worth reading on CanLII.