Pay the Kids? Pay the Spouse? When Is the Salary Actually Deductible?

Live date December 2025
Live time 12:00 p.m. – 1:30 p.m. ET
Duration 90 minutes

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Registering multiple people? Volume discounts from 10% to 25% apply automatically at checkout.

Canadian autumn forest

See what to expect

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Live session + Q&A

105 minutes of teaching plus 15 minutes of live Q&A discussion.

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Recording access

The webinar recording will be available shortly following the live event.

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Detailed slide deck

Includes tax tables, worked examples, planning notes, technical references, and supporting resource materials.

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CPD certificate

A CPD certificate is available after successful quiz completion.

Real-world planning question

When the deduction is denied, where does the money actually come from?

A family sold its business, left the proceeds in a holding company, and put a spouse and children on payroll at roughly $100,000 a year — real payroll, source deductions, T4s — for a calculated saving of about $150,000 over three years. When the deduction was denied, the family members were not reassessed and kept their employment income. The tax on the add-back landed in a corporation earning investment income, and that corporation no longer had the cash to pay it.

What we'll work through

01

Two Gates, Two Taxpayers

  • Where a salary deduction actually comes from — section 9, and a list of prohibitions
  • Paragraph 18(1)(a): did this person do something for the business?
  • Section 67 on what survives the first gate, and why partial denial is built in
  • The recipient's employment income under section 5, unmoved by the payer's denial
02

The Reasonableness Standard, and the Range It Creates

  • Gabco Ltd. v. MNR and the negative test the courts actually apply
  • Why a negative test produces a range rather than one defensible number
  • Petro-Canada: above fair market value can still be a reasonable decision
  • The court's standard against the question you ask at the client table
03

What the Evidence Decides

  • Age as evidence of what work was possible, not as a rule
  • A small amount denied, a substantially larger one allowed — and what separated them
  • Informal-procedure decisions, and the weight they can and cannot carry
  • Bank accounts, contemporaneous records, and money that came straight back
  • Sizing a salary to the basic personal amount, and how that reads
04

Pricing the Plan on Both Sides of the Ledger

  • What a denied deduction costs at small-business rates
  • Rate arbitrage, RRSP room, and CPP pensionability — spouse versus minor child
  • Who actually remits CPP on a family member's salary
  • Employer payroll and provincial health-tax thresholds across jurisdictions
  • Child Benefit clawback on a spousal salary, and when the plan turns net negative
05

Subsection 15(1) and the 2024 STEP Roundtable

  • The two scenarios CRA addressed, and the provision both answers turn off
  • What CRA assumed rather than decided
  • "Contemplated shareholder" — defined in the Act, narrow, and unlitigated
  • The trust-and-holdco space the 2024 answer does not reach
  • GAAR after the 2024 amendments: weak on these facts, but not unavailable
06

The Passive Company, and the File You Build Before Payday

  • The same test applied to investment income, and the refundable-tax trap
  • Roughly four to five times the cost, on an identical error
  • The self-reported add-back: what it buys, and what it does not
  • A market-rate benchmark — the evidence most files are missing
  • Interest from the balance-due day, and detection from a desk

The Bigger Questions Behind a Family Payroll Decision

The facts are a spouse and children on a payroll. The reasoning underneath is about purpose, quantum, and how much weight an administrative answer can carry.

Purpose and Quantum Are Different Arguments

Whether an expense was incurred to earn income, and how much of it was reasonable, are tested separately and proved differently. That separation runs well beyond family payroll.

Reasonableness Is a Range, Not a Number

A negative test behaves differently from a benchmark. Once the standard reads as a floor rather than a target, advice shifts from finding a safe figure to supporting a defensible one.

An Administrative Answer Is Not a Settled One

CRA's 2024 position rests on conditions that can fail, and leaves common structures unaddressed. Reading what an administrative answer assumed — not only what it concluded — transfers to every file.

Learn with Kim and Jay

Kim G C Moody

Tax Authority

Kim G C Moody

LinkedIn

FCPA, FCA, TEP

  • Former Chair, CBA/CPA Joint Committee
  • Former Chair, Canadian Tax Foundation
  • Parliamentary committee witness
Jay Goodis

TAX STRATEGY & OPTIMIZATION

Jay Goodis

LinkedIn

CPA, CA

  • CPA Ontario Emerging Leader
  • Parliamentary committee witness
  • National tax & keynote speaker

Questions before purchasing?

Yes. Discounts range from 10% to 25% based on the number of people registered. The volume discount applies automatically at checkout as additional registrations are added.

You'll receive a confirmation email for your registration, along with a link to access the live session.

If you cannot attend live, the recording will be made available in your CTM account shortly after the session ends, so you can watch on demand.

Yes. The detailed slide deck and supporting materials will be posted shortly before the live session. When the recording is available, you'll be notified by email.

You will have access to the recording and course materials through your CTM account for one year. CTM members can access course materials while their membership is active.

Yes. A CPD certificate is available after successful quiz completion.

Yes. We will take questions during the live Q&A portion after the teaching session.

No. CTM members don't need to register for live sessions. We'll email you the link to join automatically. If you don't see it, check your spam folder or contact us.

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