When asked whether expenses for attending a convention, seminar, luncheon meeting or other meeting incurred by an individual in the course of operating a business or an immovable are deductible under s. 9 even where there is no direct effect on profits, CRA stated:
[I]n order for an expense to be considered to be made or incurred "for the purpose of", it is not necessary to show that income actually resulted from the particular outlay or expenditure itself. It is sufficient that the outlay or expense was a part of the income-earning process.
Is there a distinction between training expenses incurred by an individual to earn property income (e.g., a triplex owner taking property management courses) versus business income? CRA responded:
[W]ith the exception of certain specific provisions … (for example, convention expenses in subsection 20(10) and the restriction on capital cost allowance for rental property in subsection 1100(11) of the Regulations), the Act does not generally provide for a distinction between an expense incurred to earn income from a business and an expense incurred to earn income from property. Consequently, where a source of income exists, either property or business income, reasonable training expenses incurred by a taxpayer to earn income from that source are generally deductible to the extent that they do not produce a lasting benefit to the taxpayer. …
Assuming that the activity of managing a triplex by an individual is commercially viable and that a source of income exists (property or business), it is our view that reasonable expenses incurred by the individual to take property management training courses to improve the individual’s knowledge in this area would be deductible in computing rental income as long as they do not provide a lasting benefit to the individual. …
Regarding a luncheon registration fee paid by a lawyer for a conference on recent case law, CRA stated (before going on to refer to the s. 67.1 limitations):
Generally, the registration fees incurred by an individual in connection with a luncheon seminar are deductible in computing income from a profession under subsection 9(1) provided that they are incurred to maintain, update or upgrade a skill for the purposes of that profession and are reasonable in the circumstances.