The two-convention limitation in s. 20(10) applies only to capital expenditures. Are expense of attending conventions which were incurred for earning income from a business not subject to this limitation? CRA responded:
Where a taxpayer has incurred expenses related to a convention in order to earn income from a business and such expenses are not capital expenditures, such expenses may be deductible in computing its business income without reference to subsection 20(10).
Historically, the CRA's position with respect to convention expenses is that such expenditures are generally capital expenditures to which paragraph 18(1)(b) applies. In addition, paragraphs 18(1)(a) and (h) and sections 67 and 67.1 could apply, depending on the circumstances.