27 March 1996 Income Tax Severed Letter 960991A - MEALS AND BEVERAGES AT GOLF CLUBS

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.

		March 27,1996

	Ed Gauthier	HEADQUARTERS
	Director General	B. Kerr
	Audit Directorate 	957-2139

		960991

Expenses incurred at a Golf Club - Subparagraph 18(1)(l)(i)

This is further to our previous letter of October 11, 1995, concerning the above-noted topic. Subsequent to the 1995 APFF round table, we had the opportunity to reconsider our position on this issue. The attached letter to the APFF and question and answer is self-explanatory.

Roy Shultis
Interim Director General
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch

Question 41

Meals consumed following a round of golf

In a technical interpretation dated November 7, 1994 (Document 9417835), Revenue Canada expressed the opinion that the cost of a business meal consumed at a golf club following a round of golf is not deductible under paragraph 18(1)(l) of the Act. On what logic is this administrative policy based, when the cost of a business meal consumed at a restaurant located away from the golf course would be deductible, in part under the provisions of paragraph 18(1)(a) and section 67.1 of the Act?

Answer by the Department

The otherwise deductible cost of the consumption of food or beverages is restricted under section 67.1 of the Act. Section 67.1 has application regardless of where a restaurant is located. Generally, the cost of food or beverages at a restaurant or dining room in a golf club is treated in the same manner as the costs at any other restaurant. However, where the consumption of beverages or food takes place at a golf club in conjunction with a game of golf or other recreational activity it is clear that subparagraph 18(1)(l)(i) is applicable. Subparagraph 18(1)(l)(i) of the Act refers to a golf course or facility, which includes the dining room of a golf club in a situation where it is used in conjunction with a game of golf or other recreational activity at the club.