28 April 2010 External T.I. 2009-0347581E5 F - Frais de formation -- summary under Know-How and Training

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, CRA stated:

Training costs are not deductible as current expenses and are considered to be capital expenditures under paragraph 18(1)(b) if the training course to which they relate provides a lasting benefit to the taxpayer. Paragraphs 2 and 3 of IT-357R2 provide some examples of training expenses that are considered to be a capital expenditure.

As stated in paragraph 9 of IT-357R2, a training course should be distinguished from a convention. Unlike a training course, which generally has a classroom format for teaching a subject in accordance with a formal course of study, a convention does not normally have a classroom format and those attending are normally not expected to study text-books, prepare assignments or take tests. In addition, a convention does not become a training course when some of its sessions take the form of workshops. Although convention expenses may provide a lasting benefit to the taxpayer, the taxpayer may deduct these expenses in computing income under subsection 20(10), subject to the limitations contained in that subsection. …

[W]here 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.

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.

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