27 November 1989 Ministerial Correspondence 74514 F - Deduction of Expenses by Musicians and Other Self-employed Performers

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.

Subject: Project P-1611 Deduction of Expenses by Musicians and Other Self-Employed Performers

We are writing in reply to your enquiry of November 15, 1989, wherein you requested our views regarding the comments and queries from the 24(1)  24(1)  regarding the following two items of expense.

a)     Travel expenses to and from auditions, and

b)     The cost of industry - related periodicals used for employment search purposes.

Our Comments

In the context of "self-employed" performers it is our opinion that travel costs to, and from, auditions would be deductible to the extent that any one of the conditions in paragraph 11(i), which apply to engagements, can be applied to auditions.

In the context of an employee, such travel costs would be denied under section 8 of the Act.

With respect to the cost of publications, it is our view that these costs should be deductible to self-employed performers (provided the taxpayer can show that the outlay was necessary for earning income), but denied to employees. In this regard most self-employed professionals, such as doctors, lawyers etc., would be allowed reasonable expenses for publications related to the earning of their incomes. However, such expenses would be denied to employees in much the same way as any other similar personal expense such as the cost of a newspaper or magazine.

We hope these comments are of assistance.

for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and IntergovernmentalAffairs Branch