6 October 1995 APFF Roundtable Q. 41, 9522560 - MEALS CONSUMED - GOLF COURSE

By services, 3 December, 2018
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Question number
0041
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Official title
MEALS CONSUMED - GOLF COURSE
Language
English
CRA tags
18(1)(l) 67.1
Document number
Citation name
9522560
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Main text

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

APFF - 1995

Question 41

Meals consumed following a round of golf

In a technical interpretation dated November 7, 1994 (Document 9417635), Revenue Canada expressed the opinion that the cost of a business meal consumed at a golf club following a round of golf is not deductible under paragraph 18(1)(l) of the Act. On what logic is this administrative policy based, when the cost of a business meal consumed at a restaurant located away from the golf course immediately after the round of golf would be deductible, in part under the provisions of paragraph 18(1)(a) and section 67.1 of the Act?

Answer by the Department of Revenue

The opinion in question issued by the Department was given based on an interpretation of the term “facility” in the English version of subparagraph 18(1)(l)(i) of the Act as including the dining room of a golf course in a situation where it is used after a game of golf and assuming that such use was incidental to the recreational activity of the golf game itself.

However, the Department has reviewed the written opinion in question and is now of the view that the term “facility” (“installation” in French) does not include the dining room of a golf club. Therefore, the cost of a business meal consumed in the dining room of a golf club following a golf game is instead subject to paragraph 18(1)(a) and sections 67 and 67.1 of the Act, the same as business meals consumed in a restaurant located away from the golf club.