14 September 2006 External T.I. 2006-0167861E5 F - Frais de représentation -- summary under Paragraph 67.1(2)(a)

A marketing and communication agency (the "Corporation"), as part of its engagements for raising awareness of client products, incurs restaurant bills, which it included in its fee quotations to the clients, but for which did not specifically include in its invoices rendered in accordance with those estimates. In finding that the s. 67.1(2)(a) exclusion did not apply, CRA noted that “the Corporation appears to provide meals in the ordinary course of its business to the participants in the various events it organizes but does not appear to receive payment for them,”