23 September 2004 External T.I. 2004-0080721E5 - Medical Expense

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.

Principal Issues: Whether the amount paid for metabolic testing, performed through a doctor's office, qualifies for the medical expense credit.

Position: Yes.

Reasons: The amount is paid to a medical practitioner in respect of medical services.

XXXXXXXXXX 2004-008072
Shaun Harkin, CMA
September 23, 2004

Dear XXXXXXXXXX:

Re: Technical Interpretation Request: Medical Expense Credit

We are writing in reply to your email of June 9, 2004 wherein you ask whether the cost of metabolic testing, performed through a medical doctor's office, qualifies for the medical expense tax credit.

Our Comments

Section 118.2 of the Income Tax Act (the "Act") provides rules for determining the amount that may be claimed, as a tax credit, in respect of medical expenses. Pursuant to paragraph 118.2(2)(a) of the Act, qualifying medical expenses include an amount paid by an individual to a medical practitioner, or a public or licensed private hospital in respect of medical services provided to the individual, the individual's spouse or common law partner, or to the individual's dependants.

Medical services include services relating to the diagnosis, treatment or prevention of disease performed by a medical practitioner acting within the scope of his or her professional training. In our opinion, metabolic testing performed through a medical doctor's office would normally be considered a medical service. Accordingly, where an individual pays an amount for metabolic testing to a medical practitioner, or to a public or licensed private hospital in respect of services provided to the individual, or to the individual's spouse, common law partner or dependant, such amount would qualify for the medical expense tax credit.

The foregoing comments represent our general views with respect to the subject matter. As indicated in paragraph 22 of Information Circular 70-6R5, the above comments do not constitute an income tax ruling and accordingly are not binding on the Canada Revenue Agency. Our practice is to make this disclaimer in all instances in which we provide an opinion.

We trust our comments will be of some assistance.

Yours truly,

Wayne Antle, CGA
for Director
Business and Partnerships Division
Income Tax Rulings Directorate

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