18 January 1990 Income Tax Severed Letter AC590025 - Deduction of Conference 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.

19(1)                                             5-9002
                                                  J.D. Jones
                                                  (613) 957-2104

JAN 18 1990

Dear 19(1)

Re: Conference on 24(1)

This is in reply to your letter of October 20, 1989, wherein you
requested our opinion on the deductibility for tax purposes
          24(1)

We advise that the deductibility for income tax purposes of a particular outlay or expense of a taxpayer depends upon the taxpayer's particular circumstances which can only be determined after a return has been filed and all relevant facts disclosed and, accordingly, we are unable to provide you with a definitive reply. However, we do offer the following comments of a general nature which may be of assistance to you.

Subsection 20(10) of the Income Tax Act specifically permits a deduction in respect of expenses incurred in attending not more than two conventions per year for taxpayers who are carrying on a business. In this regard we have enclosed a copy of Interpretation Bulletin IT-131R2 .

It would appear from the pamphlet provided that the costs incurred in attending this conference may be deductible provided the expenses claimed are reasonable and attendance relates to the professional practice carried on by you. Concerning the amounts paid to attend this convention which may be deductible from professional income, we have attached a copy of Interpretation Bulletin IT-518 and would direct your attention to paragraph 4.

We trust our comments will be of assistance to you, however, should you require further information you should contact your local district taxation office.

Yours truly,

for Director Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch

c.c. Scarborough District Office