Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.
Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.
Principal Issues: Medical expense - cost of a computer where it is used in conjunction with a device (an optical scanner) described in Regulation 5700(l)
Position: The Computer is not an eligible medical expense
Reasons: Regulation 5700(o) clearly distinguishes the computer from the devices or equipment designed exclusively to help a blind individual operate a computer - It follows that a computer is not described in Regulation 5700(l)
July 19, 2000
Rick Allen HEADQUARTERS
Ottawa Tax Services Office M. Eisner
Client Services (613) 957-2138
2000-3462
Medical Expenses
This is in reply to your memorandum of June 26, 2000, in which you asked us for our comments on a letter from XXXXXXXXXX (the "Individual").
In the letter, the Individual indicated that he has a Hewlett-Packard 6350C Scanner with related optical character recognition ("OCR") software, which through the use of a personal computer, enables him to read print. The computer owned by the Individual has increased cpu speed, ram and disk storage as a result of the computer capacity needed to operate the OCR program. As a consequence of these extra features, the Individual's computer is considerably more expensive that the average personal computer.
With respect to the 2000 taxation year, the Individual has asked whether the cost of the computer is an eligible medical expense.
Paragraph 118.2(2)(m) of the Income Tax Act (the "Act") sets out the conditions under which the devices and equipment listed in section 5700 of the Income Tax Regulations (the "Regulations") qualify as medical expenses.
For the purposes of determining whether this provision includes a computer, we have considered the wording of paragraph 5700(o) of the Regulations, which refers to a device or equipment, including a synthetic speech system, braille printer and large print-on-screen device, designed exclusively to be used by a blind individual in the operation of a computer. Since the wording clearly distinguishes between a computer and a device which assists a blind individual in using a computer, it is our view that the cost of a personal computer is not an eligible medical expense under paragraph 5700(l) of the Regulations.
In order for the cost of the Individual's computer to qualify as an eligible medical expense, an amendment to the Act would be necessary. Should the Individual wish to pursue this matter, he should contact the Department of Finance whose responsibilities include considering amendments to the Act. The address of that Department is 140 O'Connor Street, Ottawa, Ontario, K1A 0G5.
For your information, a copy of this memorandum will be severed using the Access to Information Act criteria and placed in the legislation Access Database (LAD) on the Agency's mainframe computer. A severed copy will also be distributed to the commercial tax publishers for inclusion in their databases. The severing process will remove all material that is not subject to disclosure including information that could disclose the identity of the taxpayer. Should your client request a copy of this memorandum, they can be provided with the LAD version or they may request a copy severed using the Privacy Act criteria which does not remove client identity. Requests for this latter version should be made by you to Jackie Page at (613) 957-0682. The severed copy will be sent to you for delivery to the client.
John Oulton
Manager
Business, Property & Employment Section III
Business and Publications Division
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch
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