22 November 1995 External T.I. 9528735 - TRAINING 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.

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

		952873
XXXXXXXXXX	M. Eisner

Attention: XXXXXXXXXX

November 22, 1995

Dear Sirs:

Re: Training Expenses

This is in reply to your letter of October 21, 1995 concerning the above-noted subject in relation to an ocean cruise.

You have asked us about the tax consequences of a proposed cruise which has been arranged for a group of medical people. The income tax implications in respect of proposed transactions will only be considered by this Directorate by way of an advance income tax ruling request that is described in Information Circular 70-6R2 and the related Special Release dated September 28, 1992 which have been enclosed.

However, we have also included copies of Interpretation Bulletins IT-357R2 "Expenses of Training" and IT-518 "Food, Beverages, and Entertainment Expenses". These Department publications set out general comments in relation to the information set out in your letter. As a further comment, we are mentioning that the deductibility of food, beverages entertainment which is discussed in IT-518 is now subject to the limitation of 50% rather than 80% as mentioned in that IT.

We trust our comments will be of assistance to you.

Yours truly,

P.D. Fuoco
for Director
Business and General Division
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch