CRA Rejects Unreasonable Expenses For Commissioned Employees, Despite Having Filled Out Form T2200

Overview: Why the Tax Court Denied an $86,231 Commissioned Employee Expense Deduction

Thorburn v The King, 2026 TCC 108, is a practical reminder that employee expense deductions are not allowed simply because an expense appears useful, income-producing, or supported by a Form T2200. The Tax Court of Canada dismissed Robert Thorburn’s appeal of a CRA tax reassessment denying an $86,231.25 deduction claimed for his 2014 taxation year. The claimed expense related to a business plan that Mr. Thorburn said he paid to 169335 Canada Inc. (169), a corporation he controlled, because his employer required him to prepare it. He argued that the amount was deductible under paragraph 8(1)(f) of the Income Tax Act, which permits certain commissioned employees to deduct qualifying employment expenses.