Susan owns 17% of the shares of XXX ltd. and is employed by XXX ltd as the Vice-President of Marketing. On June 15, 2020, Susan received an interest-free loan from XXX ltd. in the amount of $50,000. A loan agreement was signed by Susan in which she agreed to repay the loan on June 14, 2022. Susan used the funds from the loan to pay for her up-coming wedding. XXX ltd. has made similar loans in the past to other Vice-Presidents of the company. XXX ltd. has a December 31 year-end. Assume that the prescribed interest rate throughout 2020 and 2022 was 3%.

 

Required: Discuss the tax implications of the shareholder loan (for Susan) in 2020 and 2022. Your response should consider whether any of the exceptions to the shareholder loan rules apply and whether the imputed interest rules are applicable