The appellant, a commission-based wealth advisor, appealed reassessments denying the deduction of headhunter fees incurred to recruit a partner.
The Minister argued the expenses were not required by her employment contract and constituted outlays of capital.
The Tax Court of Canada allowed the appeal, finding that the employer's T2200 form confirmed she was required to pay business development expenses, and the recruitment fees were current expenses incurred to earn employment income, not capital outlays.