23 June 1987 Income Tax Severed Letter 5-3184 - [Deductible Medical Expenses]

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.

Revenue Canada Taxation Head Office

C. Tremblay (613) 957-2139

June 23, 1987

Dear Sirs:

This is in reply to your recent letter concerning the deduction of fees paid for your service as a deductible medical expense to your clients.

XXXX

We have considered the information set out in your letter and regret that we must conclude that the expense in question is not eligible for deduction. In order to qualify as a medical expense for the purposes of the Income Tax Act (the "Act"), there must be some provision in the Act or the Income Tax Regulations (the "Regulations") that expressly authorizes the deduction of the particular type of expense. The relevant provisions of the legislation are paragraph 110(1)(c) of the Act and Regulation 5700 copies of which are attached for your information. As you can see, the cost of the type of service your company provides is not listed as a qualifying medical expense.

We regret that our response could not be more positive, but we would stress that this Department is obliged to administer the tax laws as legislated by Parliament. We have, however, taken the liberty of forwarding a copy of your letter to our Current Amendments Division for their consideration in referring this matter to the Department of Finance which as you may know, is responsible for initiating amendments to the Income Tax Act and Regulations.

We hope this letter will be of some assistance to you.

Yours truly,

for Director

Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch

Enclosure