7 October 1997 External T.I. 9722775 - MEDICAL EX, COMPUTER WITH MAGNIFIER ATTACHMENT

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.

Principal Issues:

medical expense - cost of a computer with a magnifier attachment

Position:

computer is not a medical expense but the attachment will likely qualify, assuming that it was designed exclusively as an aid for visually impaired and device is prescribed by a medical practitioner - alternatively, if computer is contributed to partnership (was purchased to enable partner to continue working), the cost of computer is capitalized and the attachment would presumably be deductible under 20(1)(rr)

Reasons:

reg 5700(o) clearly distinguishes the computer from the devices or equipment designed exclusively to help the disabled use a computer

A. Humenuk
XXXXXXXXXX 972277

Attention: XXXXXXXXXX

October 7, 1997

Dear Sirs:

Re: Medical Devices

We are replying to your letter of August 12, 1997, in which you ask whether the cost of a computer specially adapted with a magnifier attachment qualifies as a medical expense for income tax purposes in respect of an individual, such as yourself, who is visually impaired.

Paragraph 118.2(2)(m) of the Income Tax Act (the "Act") sets out the conditions under which the devices and equipment listed in section 5700 of the Income Tax Regulations (the "Regulations") qualify as medical expenses.

Paragraphs 5700(l) and (o) of the Regulations describe devices and equipment which are of assistance to an individual with a severe visual impairment. Paragraph 5700(l) of the Regulations includes an optical scanner or similar device designed to be used by a blind individual to enable him to read print and paragraph 5700(o) includes a device or equipment, including a synthetic speech system, braille printer and large print-on-screen device, designed exclusively to be used by a blind individual in the operation of a computer. The wording of this latter provision clearly distinguishes between a computer and a device which assists a blind individual in using a computer. Accordingly, while the cost of a computer is not an eligible medical expense, the cost of a magnifier attachment will presumably qualify, provided it is a device designed exclusively as an aid for the visually impaired and the conditions of paragraph 118.2(2)(m) of the Act are met.

Alternatively, if the computer is purchased by the partnership, the cost of the computer and attachments will form part of the assets of the partnership. While the cost of the computer would have to be capitalized, paragraph 20(1)(rr) of the Act would permit a current deduction for the cost of the magnifier attachment.

We trust our comments will be of assistance to you.

Yours truly,

C. Chouinard
for Director
Business and Publications Division
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch