Client B agreed to acquire a life insurance policy from Advisor A, and Advisor A agreed to repay Client B for the accounting fees Client B incurred for the review of the life insurance policy. CRA stated:
[E]xcept as otherwise limited by the Act (e.g., section 18 and 67 …), the reimbursement of the accounting fees paid by Advisor A to Client B would generally be deductible under subsection 9(1) … in computing Advisor A’s income from business for the year in which the amount is incurred.
Client B would include the reimbursement in income pursuant to paragraph 12(1)(x) …[, a] treatment [which] would also apply if Client B did not acquire the life insurance policy.
The above was consistent with 2010-0359401C6 (where instead the advisor paid a cash rebate to the client).