I think the challenge is when you look at the definition of “reasonable”. A spouse or a family member in a business doesn't just do one thing. They do a little bit of everything. They do a little bit of marketing. They meet with customers. They clean up. They answer the phone. They help write the reports. It's difficult to say what's the appropriate salary level for that. If you're paying a family member $60,000 and CRA assesses the value of their labour at $30,000, how do you go back and prove it?
We've heard different things from business owners and accountants who say they have been successfully able to prove it under reasonableness tests. But other times, it's really hard. Poor CRA, how are they supposed to enforce this? It's a tough one.