Shareholder loans and subsection 15(2): What business owners need to know

By Igor Kastelyanets ( January 20, 2026, 2:12 PM EST) -- Have you ever “borrowed” money from your own company or paid a personal expense out of the corporate account? It might seem harmless, but the Canada Revenue Agency (CRA) has a special rule to catch this activity: subsection 15(2) of the Income Tax Act (Canada). This rule can turn those shareholder loans or benefits into taxable income. In this article, we’ll break down what subsection 15(2) is, why the CRA uses it so often, examples of how it can be triggered, how serious the consequences can be, and practical ways to avoid or defend against these tax assessments....