| May 1, 1990 | |
| Examination Division | Business and General |
| W.S. Hume | Division |
| Director | J.D. Jones |
| 957-2104 | |
| File No. 7-4709 |
SUBJECT: Commission Fees Versus Commission Income Timing
This is in reply to your memorandum of February 6, 1990, wherein you requested our opinion on your interpretation of paragraph 8(1)(f) of the Income Tax Act (the "Act") in the following situation.
24(1)
It is your view that as the taxpayer must report his income and expenses on the cash basis and as paragraph 8(1)(f) of the Act states, in part, "...amounts expended by him in the year for the purpose of earning the income from the employment (not exceeding the commissions or other similar amounts fixed as aforesaid received by him in the year)..."
24(1)
We advise that we are in agreement with your interpretation of the provisions of paragraph 8(1)(f) of the Act in the above situation for the reasons as outlined by you in your memorandum. However you may wish to consider providing administrative relief by 24(1)
B.W. Dath DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch