8 November 2011 Internal T.I. 2011-0416651I7 F - Crédit d'impôt pour frais médicaux
Principal Issues: [TaxInterpretations translation] Can interest costs incurred by a taxpayer in connection with dental implants be eligible for the medical expense tax credit?
Position: No.
Reasons: Those fees are not paid to a medical practitioner, dentist or nurse or a public or licensed private hospital pursuant to paragraph 118.2(2)(a).
November 8, 2011
Jonquière Tax Services Office Headquarters Business and Partnerships Division Attention: Johan Simard
2011-041665
Medical Expense Tax Credit - Interest Expense
This is a follow-up to your email that we received on July 25, 2011 regarding the above subject.
Unless otherwise indicated, all statutory references herein are to the provisions of the Income Tax Act (the “Act")
You described a situation where the taxpayer had surgery for dental implants. In order to finance the cost of the surgery, the taxpayer had to take out a bank loan. The taxpayer wishes to know if the interest expenses she incurred in connection with her surgical procedure may give rise to entitlement to the medical expense tax credit.
Our Comments
Pursuant to paragraph 118.2(2)(a), an individual's medical expenses are expenses paid to a medical practitioner, dentist or nurse or a public or licensed private hospital, for medical or dental services provided to the individual, the individual’s spouse or common-law partner or a dependant of the individual in the taxation year in which the expenses were incurred.
In this case, the interest expense incurred by the taxpayer in respect of dental services is not an expense paid to a medical practitioner, dentist or nurse or a public or licensed private hospital. Consequently, we are of the view that those interest expenses do not qualify for the medical expense tax credit pursuant to paragraph 118.2(2)(a).
Access to Information
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We hope that these comments are of assistance.
François Bordeleau, Advocate
Manager
Business and Partnerships Section
Income Tax Rulings Directorate