CRA considers that medical evaluations for insurers are no longer GST-exempt including where report writing in the U.S. is separately charged

CRA considers that independent medical evaluations (IMEs) supplied by non-employee doctors to insurance companies or lawyers before March 21, 2013 were exempt health supplies. Effective after that date, s. 1.2 of Part II of Sched. V was added to exclude supplies whose purpose was not patient care or treatment, so that in CRA’s view, this amendment generally rendered IMEs taxable. Where the doctor is a U.S. resident (and HST registrant) performing the exams in Ontario and preparing his report in his U.S. home office, CRA will consider there to be a single supply of an IME so that all his fee will be taxable because it was performed, in part, in Canada (and this is so even if there is a separate charge for the report preparation).

Neal Armstrong. Summaries of 8 January 2016 Interpretation 150125 under ETA Sch V, Part II, s. 1.2 and s. 1 – qualifying health care service, ETA. 142(1)(g), New Harmonized Value-Added Tax System Regulations, s. 13(1).