The resident Taxpayer visited numerous restaurants each week, and prepared reviews, which were then disseminated through various media that are the source of income for the Taxpayer's restaurant review business. Is the deductibility of the meal expenses restricted by s. 67.1? CRA responded:
The purpose of subsection 67.1(1) is to limit the deductibility of expenses for business meals and entertainment since these expenses necessarily include an element of personal consumption. In this case, since there is no exception in subsection 67.1(2) that would allow the Taxpayer to avoid the application of subsection 67.1(1) … expenses incurred by the Taxpayer for food and beverages paid for during restaurant visits should be subject to the restriction in subsection 67.1(1).