5 June 1991 Administrative Letter 910856 F - Air Filtration and Water Purification Systems -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.

Dear Sirs:

This is in reply to your letter of March 28, 1991 in which you asked whether the cost of an air filtration system   24(1)  and the cost of a water purification system   24(1)   you purchased qualify as medical expenses for the purposes of the medical expense tax credit.

From the information in your letter, we understand that the water purification system was purchased for general use in your home.  In the case of the air filtration system, you have indicated that it was purchased for your daughter who is asthmatic.

In relation to these two items, you have attached an excerpt from "Income Taxation In Canada" which states that certain items required by environmentally sensitive persons would qualify as medical expenses.  However, an additional excerpt you attached indicates that air conditioners, humidifiers, dehumidifiers, or air cleaners do not qualify as such.

Unfortunately, the latter excerpt referred to in the preceding paragraph does not appear to take a recent amendment to an Income Tax Regulation (paragraph 5700(c)) into account which relates to certain items in respect of environmentally sensitive patients and applies to 1988 and subsequent years.  Prior to the amendment, which was made on November 20, 1990, the Regulation referred to certain devices but excluded an air conditioner, humidifier, dehumidifier, or air cleaner.  However, in the revised Regulation, an air cleaner was deleted from the list of exclusions and an air exchanger was added thereto.

For a device or an item of equipment to qualify as a medical expense under the Income Tax Act, one of the requirements that must be met is that it be prescribed by a medical practitioner.  In addition, the device or equipment must be "designed exclusively for use by an individual suffering from a severe chronic respiratory ailment or a severe chronic immune system disregulation" and must not be a device that is excluded pursuant to our earlier comments.

Accordingly, it is possible for a water purification device to qualify as a medical expense.  However, for this to occur, the requirements set out in the preceding paragraph must be satisfied. For example, if a person is suffering from "severe chronic immune system disregulation", a medical practitioner could prescribe a certain water purification system which is designed exclusively for the particular medical problem involved and would permit consumption tolerance that did not previously occur.

Since it is our understanding that you purchased the water purification system for general use within your home, the cost of the system would not qualify as a medical expense for the purposes of the Income Tax Act.

In the case of the air filtration system, it is not possible to determine whether the criteria described in paragraph 5700(c) of the Income Tax Regulations has been satisfied.  In order to determine whether the device or equipment is described in that paragraph, a letter from a qualified medical practitioner should be provided indicating that the patient has a condition described in that paragraph and that the device or equipment purchased has been prescribed for that patient and is designed exclusively for an individual suffering from that condition.  In addition, a copy of the purchase invoice and a manual which is normally provided upon purchase should be provided.

For your further information, we note that "a severe chronic respiratory ailment" can include asthma.

If you wish further information concerning whether the cost of either the air filtration system or the water purification device is a qualified medical expense, you may contact Mr. Pat Colestock (Tel. (416) 973-3301) of the Toronto District Office.

We trust our comments will be of assistance to you.

Yours truly,

for Director business and General DivisionRuling DirectorateLegislative and Intergovernmental Affairs Branch