Does section 160 apply if my corporation paid me a bonus instead of a straight transfer of property?

Yes, section 160 can extend beyond a straightforward transfer of property to reach certain payments, including a bonus, made by a corporation with an unpaid tax debt to a non-arm's-length person like a shareholder or a related employee. If the payment isn't genuinely supported by adequate consideration flowing back to the corporation, for example, a bonus that doesn't reasonably correspond to actual services performed at fair value, it can be treated the same way as a below-value property transfer, exposing the recipient to personal liability for the corporation's unpaid tax.

The key question is substance rather than labelling: a genuine bonus paid for real services actually performed, at a reasonable value, is fundamentally different from a payment dressed up as a bonus specifically to move value out of a corporation with tax debts, and CRA looks at what the payment actually represents rather than simply accepting the label used on the corporation's books.

Because this risk applies to compensation decisions, not just obvious property transfers, corporations with any outstanding tax debt should be cautious about unusually large or hard-to-justify bonus payments to shareholders or related individuals, since those payments can carry the same personal exposure as an outright transfer of property for less than full value.