Words and Phrases - "day camp"
15 October 2003 External T.I. 2003-0014535 F - FRAIS DE GARDE D'ENFANTS
A corporation operating a school that is registered as a recreation and sports activity business offers a "Sports-Études" program for athletes under 16 years of age who are performing well in a particular field, every day from 3:00 p.m. to 5:00 p.m. From 5:00 pm to 6:00 pm, a daycare service is offered to 11 and 12 year olds.
It also offers a multi-sports day camp for the summer and other school holidays for children aged 6 and up. It is a recreational camp designed to entertain children during school breaks. Childcare services are offered from 7:00 am to 9:00 am and from 4:00 pm to 6:00 pm every day.
Does the multi-sports day camp qualify as a day sports school or day camp as per IT-495R2, para. 2, and do the fees incurred by parents for children registered for the multi-sports day camp, as well as the additional fees paid for using the 5:00 p.m. to 6:00 p.m. daycare services for the "Sports-Études" program, qualify as child care expenses?
After noting the exclusion in para. (d) for “education” programs, and further noting its general position that “an educational program differs from child care in that an educational program is structured to achieve certain goals, develop skills and progress through a planned program whereas there is not the same expectation for a child in child care to develop specific educational goals,” CCRA indicated that, as a matter of first impression, such fees qualified.