18 December 2002 Internal T.I. 2002-0164817 F - HONORAIRES POUR SERVICES DE MANDATAIRE -- summary under Income-Producing Purpose

A professional paid his management company for 115% of the costs it purportedly incurred in managing his professional practice. However, the employees engaged in the provision of such services were employed by him and the management agreement was not signed. The Directorate indicated that, on this basis, it could be considered that such fees were non-deductible pursuant to s. 18(1)(a).