One has to wonder about CRA. Their analysis and approach on Canadian Controlled Private Corporations was awful regardless of what you might think about the policy position. And changing the bar on employee discounts from below-cost to less-than-publicly-available-discounts wonders who the hell championed this turkey within CRA. The test might have been raised to fair market value but that is just as hard to determine as publically available discounts. Below cost is a much easier test. 

From a political viewpoint why the hell go after hard working employees when we have a lot to be concerned about in the real estate market and off shore money.  CRA bureaucrats wake up!