Are expenses that simply make the taxpayer available to the business considered business expenses?
Canada (Federal), Canada
The following excerpt is from Rouillard v. The Queen, 1999 CanLII 475 (TCC):
In Symes v. Canada, 1993 CanLII 55 (SCC), [1993] 4 S.C.R. 695, Iacobucci J. conducted a lengthy analysis of both personal and business expenses. While we are not concerned here with business income, it is nevertheless interesting to see whether the expense in question would be allowed as a business expense. It would appear that it would not, based on Iacobucci J.'s finding at page 739, and I quote: . . . Traditionally, expenses that simply make the taxpayer available to the business are not considered business expenses since the taxpayer is expected to be available to the business as a quid pro quo for business income received. . . .
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