13 July 1990 Income Tax Severed Letter ACC9436 - Deductibility of Medical Expenses in respect of Special Schooling

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.

SAINT JOHN DISTRICT OFFICE                  J.A. Szeszycki
                                            Rulings Directorate

R.D. Leger                                  900089 

Deductibility of Medical Expenses
in respect of                      19(1) 

We are enclosing for your information a copy of our correspondence with 19(1) who has asked us to provide a ruling or opinion with respect to the deductibility of amounts paid in connection with 24(1)

As you will note from our response to 19(1) we have indicated that the application of paragraph 118.2(2)(e) of the Act hinges on whether the school, qualifies as one that specially provides the facilities, equipment, or personnel required for the care and training of individuals suffering from the condition described in his submission. In an effort to resolve the matter we requeste 19(1) to submit a brochure or similar document that describes how the school meets the criteria set out above. To date we have not received the requested information and have, therefore suggested in our response that when the information becomes available he should submit it to the District Taxation Office for the final determination.

Should your staff require any further assistance from this office please contact Jack Szeszycki at (613) 957-2103.

B.W. Dath Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch