A self-employed financial products broker receives commissions for the sale of life insurance policies that he takes out for his own benefit (the persons insured are members of his family and the beneficiaries are either him or his spouse). The broker is responsible for the payment of the related premiums. Are these premiums deductible in computing his income from a business? After finding that the commissions generated by the broker were income to him given their substantial amount, CRA stated:
[T]he insured persons being members of the broker's family, CRA is of the view that such premiums are a personal expense that is not deductible under paragraph 18(1)(h).