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.
MINISTER/DEPUTY MINISTER'S OFFICE 95-06925M
ADM'S OFFICE
RETURN TO 15TH FLOOR, ALBION TOWER
October 27, 1995
XXXXXXXXXX
Dear XXXXXXXXXX:
I am writing in reply to your letter of September 13, 1995, concerning the deductibility of the costs of cruises by realtors and investors when there is an educational component of the cruise. This topic was the subject of an article in a recent real estate weekly.
I note that the authority for a tax deduction for this type of cruise has been attributed to an unnamed accounting firm and not to Revenue Canada.
In the Department's view, expenses relating to the cost of the cruise itself would be personal and, therefore, not deductible. For real estate investors, the overall cost of the cruise including any seminars would not be deductible. For self-employed realtors, that portion of the cost that could be directly attributed to the seminar itself could be deductible. As a rule, expenses of attending a training course outside a taxpayer's general geographic locale are considered unreasonable to the extent that they exceed what they would have been had a similar course been attended locally, if available. The majority of the cost of the cruise would not be deductible under any circumstance.
I wish to thank you for bringing your concerns to my attention.
Yours sincerely,
David Anderson, P.C., M.P.
A.M. Brake
957-2133
October 13, 1995