14 March 2010 External T.I. 2011-0397151E5 - Medical Expense Tax Credit - Dental Implants

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.

Principal Issues: Whether the cost of dental implants would qualify as medical expenses for purposes of the METC.

Position: Yes, provided the payment is made to a medical practitioner or dentist.

Reasons: Payments made to a "medical practitioner" or a "dentist", who is a person authorized to practice as such pursuant to the laws of the jurisdiction in which the service is rendered, would generally constitute a medical expense for purposes of paragraph 118.2(2)(a). Some of these payments may qualify as medical expenses pursuant to paragraph 118.2(2)(o), for laboratory, radiological or other diagnostic procedures, if they have been prescribed by a medical practitioner or a dentist.

XXXXXXXXXX 			2011-039715
				S. D'Angelo
March 14, 2011

Dear XXXXXXXXXX :

Re: Medical Expense Tax Credit - Dental Implants

This is in response to your correspondence of February 23, 2011, inquiring about whether costs incurred for dental implants will qualify as medical expenses for purposes of the medical expense tax credit ("METC").

The particular situation outlined in your letter appears to relate to a factual one, involving one or more specific taxpayers. As explained in Information Circular 70-6R5, it is not this Directorate's practice to comment on transactions involving specific taxpayers other than in the form of an Advance Income Tax Ruling. An Advance Income Tax Ruling is not issued where a transaction has been completed or is significantly advanced. In those instances you should submit all relevant facts and documentation to the appropriate Tax Services Office for their views. However, we are prepared to offer the following general comments which may be of assistance.

Our comments

Pursuant to paragraph 118.2(2)(a) of the Act, an amount is considered to qualify as a medical expense of an individual only if it is paid to a medical practitioner, dentist or nurse, or a public or licensed private hospital in respect of a medical or dental service. In this regard, a medical service is a service relating to the diagnosis, treatment or prevention of disease performed by a medical practitioner acting within the scope of his or her professional training. Similarly, a dental service generally relates to the treatment of an individual's teeth.

Payments made to a "medical practitioner" or a "dentist", who is a person authorized to practice as such pursuant to the laws of the jurisdiction in which the service is rendered, would constitute a medical expense for the purpose of paragraph 118.2(2)(a) of the Act, provided the payments are in respect of medical or dental services. Some of these payments may qualify as medical expenses pursuant to paragraph 118.2(2)(o) of the Act, for laboratory, radiological or other diagnostic procedures, if they have been prescribed by a medical practitioner or a dentist. As such, the cost of dental implants paid to a medical practitioner or dentist would likely qualify as medical expenses for purposes of the METC.

We trust our comments will be of assistance.

Yours truly,

G. Moore
For Director
Business and Partnerships Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch