13 September 1993 Administrative Letter 9317206 F - Business Expense - Deduction

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.

H.K.Beauchemin Financial Industries Director

Maureen Shea-DesRosierssGeneral Division Client Assistance Directorate

Corporate Deductibility of Costs for Cardio-Pulmonary Resuscitation (CPR) Courses

This is in reply to your Memorandum of June 9, 1993 concerning the above-mentioned subject. We apologize for the delay in replying to your Memorandum.

You inquire as to whether the costs incurred by a corporation in providing CPR courses to its employees would be deductible as a business expense in computing the corporations's income. The estimated tuition fee for the course is $25 per employee.

An expense is only deductible by a taxpayer pursuant to the Income Tax Act if it is (a) an expense of the taxpayer, (b) made or incurred for the purposes of earning income from a business or property of the taxpayer, (c) reasonable in the circumstances and (d) not an outlay of a capital nature.

In our view, the cost of such a course, provided by an employer to some of its employees at its request to ensure the health and physical safety of its employees at the workplace, is part of its income-earning process, and therefore is deductible, including the expenses of providing the course outside the employer's place of business, provided that they are reasonable in the circumstances.

On the other hand, where an employee takes such a course on his or her own, and not as part of the health and physical safety program of an employer, we are of the view that the reimbursement to the employee of the cost of the course would generally be a taxable benefit to the employee.

We trust the above comments will be of assistance to you.

Director Financial Industries DivisionRulings Directorate