Silber – Court of Quebec finds that a stock broker could deduct costs of sponsoring his cycling team from employment income

A commissioned stock broker employed by CIBC Wood Gundy (Silber) founded a team of around 10 professional cyclists, known as "Silber Pro Cycling" and, in 2015 and 2016, paid the team $265,000 and $330,302, respectively, in his capacity of principal team sponsor. The ARQ denied his deduction of the sponsorship expenses under the equivalent of ITA s. 8(1)(f) on the basis that they were not expended by him for the purpose of earning his employment income.

In allowing Silber’s appeal, Richard J noted inter alia that, in return for his sponsorship, Silber obtained exposure for his name and practice in a number of ways including the teams’ name, logo, website name, and both his and his employer’s names being prominently displayed on the cyclists’ clothing.

Neal Armstrong. Summary of Silber v. Agence du revenu du Québec, 2023 QCCQ 127 under s. 8(1)(f).