| Client Assistance Directorate | Financial Industries |
| H.K.Beauchemin | Division |
| Director General |
Attention: Rick Owen
Corporate Deductibility of Costs for Cardio-Pulmonary Resuscitation (CPR) Courses
Further to our telephone conversation(Owen/Shea-DesRosiers) of September 21, 1993, concerning our reply of September 13, 1993 to your memorandum of June 9, 1993 on the above-subject (our file 7-931720), we have the following comments in response to your queries:
1. In paragraph 4, line 1 of our letter, we use the word "some" to include all the employees who have to take the CPR course at the request of the employer to ensure the health and physical safety of the working place. It is not limited to a particular number or group.
2. In the last paragraph of our letter, the reimbursement of the cost of the course to the employee by the employer would be deductible to the employer pursuant to paragraph 18(1)(a) of the Income Tax Act (see Interpretation Bulletin IT-357R2, number 7).
We trust the above comments clarify our previous memorandum.
Chief Financial Industries DivisionRulings Directorate