910350
Dear Sirs:
Re: Employee Fringe Benefits - Commission Sales
This is in reply to your letter dated January 24, 1991 in which you requested our view regarding the taxation of commissions received in situations where a broker or agent purchases life or disability insurance coverage for himself or a family member.
Enclosed is a copy of Interpretation Bulletin IT-470R which discusses the Department's position on this matter. As stated in paragraph 27, where a life insurance salesperson acquires a life insurance policy, any commissions received by the salesperson on that policy are not taxable provided the salesperson owns that policy and is obligated to make the required premiums payments. As long as the salesperson owns the policy and is obligated to pay the premiums, it is immaterial whose life is insured under the policy.
We trust our comments will be of assistance to you.
Yours truly,
for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch