13 May 1993 Income Tax Severed Letter 930358A F - Seminar 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.

XXXXXXXXXX

Attention:  XXXXXXXXXX

Dear Sirs:

RE:  Deductibility of Seminar Expenses

This is in reply to your letter of February 5, 1993 concerning the deductibility of seminar expenses by XXXXXXXXXX

The seminars to be conducted by the

XXXXXXXXXX

You refer to Interpretation Bulletin IT-131R2.

It appears that the interpretation you seek relates to a proposed transaction to be undertaken by a specific taxpayer and, therefore, we bring to your attention Information Circular 70-6R2 dated September 28, 1990 issued by Revenue Canada, Taxation. Confirmation with respect to proposed transactions involving specific taxpayers will only be provided in response to a request for an advance income tax ruling. If you wish to obtain an advance income tax ruling for a particular taxpayer with respect to specific transactions which are contemplated, a written request for an advance income tax ruling can be submitted in accordance with the Information Circular. Nevertheless, we can offer the following general comments.

OUR VIEWS

Interpretation Bulletin IT-131R2 explains the deduction provided under subsection 20(10) of the Income Tax Act ("the Act") in respect of convention expenses. Paragraph 1 of IT-131R2 defines a convention as a formal meeting of members for business or professional purposes. As the seminars which you propose will offer business related education to improve operations such seminars would not be considered conventions. These seminars would be in the nature of training. The deductibility of the costs and expenses of training is discussed in IT- 357R2.

As regards your two specific questions it is our view that:

(a)     As XXXXXXXXXX operates within the province of British Columbia it would not, for purposes of subsection 20(10) of the Act and IT- 131R2, be considered to be international in nature.

(b)     The seminars you describe in your letter would be considered training and not conventions. IT-357R2 describes the deductibility of costs and expenses of training.

We trust our comments will be of assistance.

Yours truly,

R. Albert for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch