Section 67.1

Subsection 67.1(1) - Expenses for food, etc.

Cases

Canada v. Stapley, 2006 DTC 6075, 2006 FCA 36

The taxpayer, who was a real estate agent, was only entitled to deduct one-half of the cost of gift certificates for food and beverages, and of...

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See Also

Rogers v. The Queen, 2014 DTC 1109 [at at 3230], 2014 TCC 101 (Informal Procedure)

Lyons J found that the taxpayer's arguments about the reasonableness of her meal costs as business expenses were irrelevant given the clear...

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Stogrin v. The Queen, 2012 DTC 1021 [at at 2599], 2011 TCC 532 (Informal Procedure)

The taxpayer argued that the 50% limitation on meal expense deductions in s. 67.1 was discriminatory because it did not produce a roughly...

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Transport Baie-Comeau Inc. v. The Queen, 2008 DTC 2839, 2006 TCC 108

The taxpayer, a long-haul trucking company, ceased to reimburse its drivers for their meal expenses and commenced paying them an additional...

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Powrmatic du Canada Ltée, 94 DTC 1206, [1994] 1 CTC 2274 (TCC)

The taxpayer, which ran sales contests enabling its customers to be sent on trips to Latin America at discounted prices to them, was not precluded...

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Administrative Policy

5 October 2018 APFF Roundtable Q. 8, 2018-0768791C6 F - Frais de repas

CRA effectively confirmed that by virtue of the combined operation of s. 8(4) and s. 67.1(1), the deduction for when a commissioned employee takes...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 8 - Subsection 8(4) commissioned employees can deduct only 25% of the restaurant tab when they take out a client in the city 213

9 April 2018 External T.I. 2017-0714381E5 F - Application de l'article 67.1

Are amounts paid by a hockey player recruiter in the course of his employment for the purchase of tickets to attend hockey games subject to s....

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Words and Phrases
entertainment

4 November 2014 External T.I. 2014-0521211E5 F - Cartes-cadeau d'une chaîne de supermarchés

A corporation which promotes the sale of non-food products provides individuals who attend its product presentations with gift cards. The cards...

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5 June 2013 Internal T.I. 2013-0490941I7 F - Expenses for food 67.1(1)

Is the agreement between the CRA and the Canadian Construction Association and the Canadian Association of Oilwell Drilling Contractors (released...

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22 October 2012 External T.I. 2012-0452491E5 F - Repas fournis dans le cadre d'une formation

As part of the carrying on of its training business, the taxpayer provides breakfast and dinner, as well as a coffee break. Respecting the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(a) Pink Elephant followed/potential exception for training business where it breaks out meals on its invoices 212
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Know-How and Training training expenses deductible (subject to s. 67.1(1)) provided that no new skill or qualification is acquired 149
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) deductibility of meal portion of training charges may be denied under s. 18(1)(h) 114

1 June 2010 External T.I. 2009-0333481E5 F - Frais d'aliments et de boissons

The resident Taxpayer visited numerous restaurants each week, and prepared reviews, which were then disseminated through various media that are...

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4 March 2010 Internal T.I. 2009-0337381I7 F - Sens du mot divertissement

Does the s. 67.1 limitation apply where a taxpayer trying to secure contracts from a customer provides the individual responsible for contracts...

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Words and Phrases
entertainment
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) gifts of entertainment equipment by taxpayer to an employee of a customer responsible for purchases are includible in that individual’s income 63

6 November 2007 Internal T.I. 2005-0152091I7 F - Frais de déplacement - activité de divertissement

The taxpayer provided periodic events for its top representatives, who were independent contractors. The Directorate, after referring to the...

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8 November 2007 External T.I. 2006-0181621E5 F - Article 67.1 - Frais de transport et de logement

The taxpayer bears the expenses of inviting major customers to an event (described as an ”entertainment activity”) , including meal expenses,...

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2 March 2007 External T.I. 2006-0185471E5 F - Frais de représentation - 67.1

CRA confirmed that a modified version of a 1998 agreement between the Commission de la Construction du Québec (the "CCQ") and CRA was in effect. ...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 236 - Subsection 236(1) ITA s. 67.1 agreement as to portion of remote work site daily allowances to be treated as for meals rather than accommodation also applies to ETA s. 236 246

2 January 1994 Ministerial Letter 9405318 - DEDUCTIBILITY OF RESTAURANT MEALS

Gift certificates constitute food expenses, the deductibility of which is governed by s. 67.1(1).

Subsection 67.1(1.1)

Administrative Policy

10 November 2010 External T.I. 2010-0364751E5 F - Frais de repas des camionneurs

Respecting the effect of the amended version of s. 67.1(1.1) applicable to amounts paid or become payable after March 18, 2007, CRA noted that it...

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Subsection 67.1(2) - Exceptions

Paragraph 67.1(2)(a)

See Also

Nicholls v. The Queen, 2011 DTC 1295 [at at 1666], 2011 TCC 39

The taxpayer carried on a business of providing information technology training courses, many of which were provided at a hotel where breakfast...

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Administrative Policy

22 October 2012 External T.I. 2012-0452491E5 F - Repas fournis dans le cadre d'une formation

As part of the carrying on of its training business, the taxpayer provides breakfast and dinner, as well as a coffee break. CRA first noted:

In

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(1) trainees required to break out meal portion of their invoices even if not separately identified 86
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(b) - Capital Expenditure v. Expense - Know-How and Training training expenses deductible (subject to s. 67.1(1)) provided that no new skill or qualification is acquired 149
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(h) deductibility of meal portion of training charges may be denied under s. 18(1)(h) 114

21 November 2014 External T.I. 2014-0553081E5 - Paragraph 67.1(2)(a)

In Pink Elephant, the exception in s. 67.1(2)(a) was applicable to a taxpayer who provided information technology training courses to its clients,...

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4 March 2014 External T.I. 2014-0519051E5 - Meals and Entertainment Expenses

The Company is required to provide meals (i.e., hot meals, beverages, snacks, fruit etc.) to employees during certain events (not described), and...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(d) "paying customers" required 83

14 September 2006 External T.I. 2006-0167861E5 F - Frais de représentation

A marketing and communication agency (the "Corporation"), as part of its engagements for raising awareness of client products, incurs restaurant...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(c) "specifically notified in writing" requirement is not satisfied where restaurant bills are included in fee estimates to clients but not explicitly in the ultimate invoices 196

11 April 2003 External T.I. 2002-0173065 F - REPAS FOURNIS COURS SEMINAIRES

A corporation provides training courses to groups ranging from 5 to 20 participants and charges fees which include continental lunches and coffee...

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16 May 1994 External T.I. 9407985 - TAVERNS PROVIDING FREE BEVERAGES

"Since the ordinary course of business of taverns is presumably to carry on a business of providing beverages for a compensation or an...

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23 June 1992 T.I. 921136 (December 1992 Access Letter, p. 16, ¶C56-205)

The limitation in s. 67.1 generally would apply to expenditures of a radio broadcasting business on obtaining concert tickets or food or...

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2 July 1991 T.I. (Tax Window, No. 5, p. 1)

A person in the business of providing dance instruction in conjunction with organized tours is not exempt under s. 67.1(2)(a) because the meals...

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Paragraph 67.1(2)(c)

See Also

Kelowna Flightcraft Air Charter Ltd. v. The Queen, 2003 DTC 611, 2003 TCC 347

The taxpayer, which chartered out its aircraft to customers, paid the crew a per diem meal allowance. The meal allowance was deductible in full to...

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Administrative Policy

GI-197 “Out-of-Pocket Expenses” 17 December 2021

In the context of a discussion of the treatment of expenses incurred by a supplier of services to a client otherwise than as agent for the client,...

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Locations of other summaries Wordcount
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Supply 621
Tax Topics - General Concepts - Agency listing of expenses typically not incurred as agent 172
Tax Topics - Excise Tax Act - Section 236 - Subsection 236(1) no limitation where specific reimbursement per ITA s. 67.1(2)(c) 183

14 September 2006 External T.I. 2006-0167861E5 F - Frais de représentation

A marketing and communication agency (the "Corporation"), as part of its engagements for raising awareness of client products, incurs restaurant...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(a) taxpayer is not considered to receive compensation for restaurant bills where they are included in its estimates but not explicitly in its invoices 93

14 November 2001 External T.I. 2001-0086765 F - FRAIS DE REPRESENTATION-EXCEPTION

Canadian corporations incurred entertainment expenses in promoting foreign products, and bill their promotional costs to the foreign producers,...

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28 May 2001 Internal T.I. 2001-0066147 F - ALIMENTS - MACHINES DISTRIBUTRICES

In the lunchroom for its plant, the taxpayer sells food and beverages purchased by it to its employees through vending machines leased by it. The...

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Paragraph 67.1(2)(d)

See Also

Les Investissements Nolinor Inc. v. ARQ, 2023 QCCQ 3835

The taxpayer, which carried on a business of providing charter flights to generally remote locations, e.g., in Nunavut or Gabon, paid its pilots,...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 20 - Subsection 20(1) - Paragraph 20(1)(e.2) taxpayer in substance was the policyholder of the assigned policy 104

Administrative Policy

18 December 2013 Internal T.I. 2012-0472211I7 F - Voyages offerts par une compagnie

The corporate "Taxpayer" annually offers an annual free trip to a southern location (perhaps a Caribbean resort) to its associated brokers and...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) Caribbean sales incentive trip provided to incorporated sales reps represents a benefit to them from their corporation 392
Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(4) - Paragraph 67.1(4)(b) Caribbean sales incentive trip is "entertainment" 175
Tax Topics - Income Tax Act - Section 9 - Nature of Income Caribbean sales incentive trip provided to incorporated sales reps was s. 9 income to their corp to extent of personal portion 171

4 March 2014 External T.I. 2014-0519051E5 - Meals and Entertainment Expenses

The Company is required to provide meals (i.e., hot meals, beverages, snacks, fruit etc.) to employees during certain events (not described), and...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(a) "paying customers" required 83

13 June 2003 External T.I. 2002-0177045 F - BOISSONS OFFERTES AUX EMPLOYES

CCRA indicated that because the free provision by the employer of beverages was primarily for the benefit of the employees, there was a taxable...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) FMV of free beverages marketed by employer and provided to its employees included in their income 86

6 August 2002 Internal T.I. 2002-0130897 F - RECOMPENSES ES QUASI-MONETAIRES

Would an employer who makes gifts to its employees of the purchase of a meal or a ticket to a show in reliance on CCRA’s new policy in Income...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) gift cards and smart cards with spendable balances do not come within the ITTN 25 gifts policy 86
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(l) - Subparagraph 18(1)(l)(ii) s. 18(1)(l)(ii) applies irrespective whether the membership is an employer gift within the ITTN 25 gifts policy 109

18 January 1996 External T.I. 9502975 - MEAL EXPENSES

Meal reimbursements and allowances paid to employees who are transport drivers would generally be subject to s. 67.1(1) by virtue of not being...

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17 February 1995 External T.I. 9504495 - MEAL EXPENSE REDUCTION

General discussion of the relationship between s. 67.1(2)(d) and s. 6(6).

Paragraph 67.1(2)(e)

See Also

Racco Industrial Roofing Ltd. v. R., 97 DTC 331, [1997] 2 CTC 3055 (TCC)

The Minister was unsuccessful in an argument that reasonable per diem meal allowances paid by the taxpayer to its employees did not qualify for...

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Administrative Policy

17 September 1996 Memorandum 961800 (C.T.O. "Allowances v. Meals")

Allowances for board and lodging that are exempted from tax in the hands of an employee working at a special work site under s. 6(6)(a)(i) are not...

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11 December 1995 Internal T.I. 9518687 - MEALS AND BEVERAGE

The 'place of business' refers to the location where these employees are considered to be employed, i.e., the employee's normal place of...

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16 February 1995 Internal T.I. 9501607 - MEAL ALLOWANCE REDUCTION

The practice in the film and television industry of feeding actors and crew during filming would give rise to a taxable benefit to them under s....

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8 August 1994 External T.I. 9410525 - FOOD AND BEVERAGE EXPENSES

The place where an event is held, such as conference facilities, do not constitute a "particular place of business" for purposes of s. 67.1(2)(e)....

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19 January 1994 External T.I. 9319595 F - Restaurant Meals

A site which qualifies as a "special work site" for purposes of s. 6(6) should also qualify as a "particular place of business". RC will require...

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17 July 1991 T.I. (Tax Window, No. 6, p. 12, ¶1355)

The longer the time required to complete a contract at customers' premises located outside the municipality where the employer's head office is...

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18 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 20, ¶1096)

Where the location or lack of catering facilities prevents the employer from directly providing the food, the employees can provide their own food...

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Paragraph 67.1(2)(f)

Administrative Policy

22 January 2010 Internal T.I. 2009-0346971I7 F - Événement ayant lieu dans un club de golf

At a golf day organized for all its employees, the company pays for the green fees, the rental of golf equipment, and the food (shown separately...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 18 - Subsection 18(1) - Paragraph 18(1)(l) - Subparagraph 18(1)(l)(i) “facility” does not include a golf club's dining room, reception rooms, conference rooms, lounges or bar 175

17 December 2002 External T.I. 2002-0158165 F - REPAS DE FETE OFFERTS PAR L'EMPLOYEUR

CCRA indicated that where an employer invites to a restaurant at the end of each month employees who have celebrated their birthday during that...

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Words and Phrases
place of business

Subsection 67.1(4) - Interpretation

Paragraph 67.1(4)(a)

Administrative Policy

23 September 1996 Memorandum 961978 (C.T.O. "Food Served by Airlines")

The exemption in ss.67.1(4) and 67.1(2)(a) would cover the cost of food and beverages served by an airline prior to boarding, and between stops...

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Paragraph 67.1(4)(b)

Administrative Policy

18 December 2013 Internal T.I. 2012-0472211I7 F - Voyages offerts par une compagnie

The corporate "Taxpayer" annually offers an annual free trip to a southern location (perhaps a Caribbean resort) to its associated brokers and...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) Caribbean sales incentive trip provided to incorporated sales reps represents a benefit to them from their corporation 392
Tax Topics - Income Tax Act - Section 67.1 - Subsection 67.1(2) - Paragraph 67.1(2)(d) Caribbean sales incentive trip provided to incorporated sales reps excluded if s. 6(1)(a) benefit to them qua employee 178
Tax Topics - Income Tax Act - Section 9 - Nature of Income Caribbean sales incentive trip provided to incorporated sales reps was s. 9 income to their corp to extent of personal portion 171

13 December 2004 Internal T.I. 2004-0097931I7 F - Définition de Divertissement - 67.1(4)

A corporation makes available to all its employees a fitness centre that it operates on the premises of its place of business and incurs related...

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Subsection 67.1(5) - Definitions

Long-haul truck

Administrative Policy

3 June 2014 External T.I. 2014-0518911E5 F - Grand routier / long-haul truck

Does the gross vehicle weight rating refer to the loaded capacity and does it include the weight of a trailer? CRA stated (TaxInterpretations...

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