In affirming its policy in IT-233 respecting the deductibility of premiums under an overhead expense insurance policy, CRA stated:
As stated in paragraph 4 of the Bulletin, where a policy covers other risks in addition to overhead expenses, the premium for the “overhead expense insurance” part of the policy will be allowable as described in paragraph 2, provided that the taxpayer furnishes sufficient evidence to enable that part of the premium to be ascertained.