Reasonable Return
Amount derived, directly or indirectly, from a related business in respect of the specified individual in a given taxation year that:
- meets the definition of “split income” in respect of the specified individual for the year, except for the following two conditions given in the definition of “excluded amount” (see the full definition in Part 6 of the Guide to Filing the Trust Income Tax Return (TP-646.G-V):
- if the individual reached age 17 but not age 24 before the year, the amount is a reasonable return in respect of the individual, taking into account only the individual's contributions of arm's-length capital,
- if the individual reached age 24 before the year, the amount is a reasonable return in respect of the individual;
- is reasonable given the following factors relating to the relative contributions of the specified individual to the business and those of each source individual:
- the work performed for the business,
- the property contributed, directly or indirectly, to the business,
- the risks assumed in respect of the related business,
- the total of the amounts paid or payable, directly or indirectly, by any person or partnership to, or for the benefit of, the specified individual or a source individual in respect of the related business, and
- any other relevant factors.
Note
End of note
Arm's-length capital
Property, or property substituted for the property, of a specified individual that is not:
- acquired by the individual as income from, or a taxable capital gain or profit from the disposition of, another property that is derived, directly or indirectly, from a related business in respect of the individual;
- borrowed by the specified individual under a loan or other indebtedness; or
- transferred to the specified individual from a person who was related to the specified individual (other than as a consequence of the death of a person).