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 statement made in document 2023-0974081E5 which stated that an automated cycler used for peritoneal dialysis did not appear to be an ‘artificial kidney machine’ under 118.2(2)(i) or a device that is described in the Act or Regulations is correct?
Position: The statement made in document 2023-0974081E5 regarding automated cyclers appears to have been made in error.
Reasons: Previous positions have historically viewed an automated cycler machine that is used for peritoneal dialysis to be an artificial kidney machine as contemplated in paragraph 118.2(2)(i).
XXXXXXXXXX 2025-106211
Randa El-Kadi
May 6, 2025
Dear XXXXXXXXXX:
Re: Amounts paid for an automated cycler for peritoneal dialysis
We are writing in response to our letter to you, dated October 23, 2023 (file number 2023-097408), in which our Directorate provided comments regarding the eligibility of amounts paid for a generator for purposes of the medical expense tax credit (METC). The generator will be permanently affixed to your existing dwelling and is to be installed in order to power an automated cycler machine during power outages. The automated cycler machine is used to assist with daily peritoneal dialysis treatments for kidney failure.
In our letter, we stated that the cost of a generator, including installation, would not qualify as an eligible medical expense under paragraph 118.2(2)(i) of the Income Tax Act (the Act), even if it was bought and used to aid with the operation of an artificial kidney machine during power outages. The conclusion reached in our letter regarding the ineligibility of the generator for purposes of the METC has not changed.
However, in our letter, we also commented that an automated cycler machine did not appear to be an “artificial kidney machine” and was not specifically listed as an eligible device for purposes of the METC. We have reconsidered the comments we provided regarding the automated cycler machine for purposes of the METC and are writing to inform you that our previous comments in that regard were made in error. In our view, an automated cycler machine would fall within the meaning of an artificial kidney machine under paragraph 118.2(2)(i) of the Act. Therefore, the cost of the automated cycler machine would qualify as an eligible medical expense.
We apologize for any inconvenience that our previous comments may have caused.
Yours truly,
Eric Wirag, CPA, CMA
Manager, Tax Credits and Ministerial Issues
Business and Employment Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch
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