The good folks at the Canada Revenue Agency were given very broad discretion to sort of paint just based on the facts, as it were. Don't you think it would have been more precise to simply ask whether company A and company B were related, or whether there was a relationship between the two, as opposed to amending it to look only at a question of facts and let CRA decide “Oh, well, maybe, maybe not”, or at least list a series of factors that would predispose CRA to including this in an employee's taxable income?
On May 25th, 2023. See this statement in context.