The manager of an agency for a life insurance company, who earned commissions based on the sales made by the salespeople under his direction, incurred fees of an accounting firm in order to hold tax conferences at the office for the salespeople and, in addition, consulted with them to obtain information and advice for client files.
In finding that such fees were deductible by the manager under s. 8(1)(f), the Directorate noted that the income of the manager depended largely on the effectiveness of the salespeople and that such expenses represented, in part, training costs incurred to update or improve their skills. The fees paid for consultations related directly to the manager’s employment activities.
The manager also incurred fees to attend a conference on advanced life underwriting at which he attended various exhibitions and presentations. The Directorate indicated that the presentations and exhibitions at the convention were primarily intended to enable participants to acquire new skills, learn about new developments or simply meet people or make themselves known so that, consequently, the expenditures were capital expenditures as they provided a lasting benefit to the manager.