3 October 2006 External T.I. 2006-0204181E5 F - Déduction de frais de thérapie -- summary under Paragraph 118.4(1)(c)

An individual who had received training in the use of the massager, but was not a health professional licensed to practise under the applicable provincial legislation, wished to set up a “Vertebrotherapy Centre” that would use the massager to relax the user while improving blood circulation, clearing QI energy channels and relieving muscle tension. After indicating that fees to clients would not qualify under s. 118.2(2)(a) because the individual was not a health practitioner, CRA reviewed the requirements of ss. 118.2(2)(l.9) (including its interpretation in Herzig) and 118.4(1)(c) noted inter alia that “no other activity, including work, housework, and social or recreational activities, is considered a basic activity of daily living.”