If there are two shareholders and only one shareholder loan account, CRA may examine the combined account and assess a value to each shareholder. If one shareholder is found to be in a debit balance (the shareholder owes the corporation money), CRA may assess them with a taxable benefit even if the combined balance is a credit (the corporation owes the shareholder money).

On the flip side, if you have just one shareholder but keep numerous shareholder loan accounts for bookkeeping purposes, CRA is now viewing each account separately. If some of the accounts are debit and others are credit balances, they will take the view that you have withdrawn money from the company and assess it as income, separate from any money you have injected into the company. If you keep numerous shareholder loan accounts for one shareholder for bookkeeping purposes, amalgamate the accounts together in your accounting records, or sign a shareholder resolution stating that the accounts should be considered netted against each other for income tax purposes. Each shareholder should have a separate shareholder loan account and work to keep the balance at zero or in a credit position to avoid being assessed a taxable benefit.