Question juridique clé
Whether the association’s member contributions were taxable income rather than exempt membership fees
Solution extraite
The contributions were not exempt membership fees because they were tied to concrete, individually attributable reciprocal services.
Motifs extraits
The association’s actual activity differed from its statutes; members received insurance-like, advisory and brokerage services in exchange for the payments, so the statutory requirements for tax-free membership contributions were not met.