Sched V, Pt. VI, s. 18 has similar wording to ITA s. 8(1)(i)(i), which provides for the deductibility of “annual professional membership dues the payment of which was necessary to maintain a professional status recognized by statute.” After the Excise and GST/HST Rulings Directorate queried the view in 2014-0530691E5 that:
a professional status would generally have to be acknowledged in the statute itself to satisfy the “recognized by statute” condition in subparagraph 8(1)(i)(i) … .
the Income Tax Rulings Directorate changed course and concluded:
[F]or purposes of the meaning of the phrase “professional status recognized by statute” … applying a textual, contextual and purposive analysis, a “professional status” can be “recognized by a statute” for purposes of subparagraph 8(1)(i)(i) … even if it is only recognized in the supporting regulations of an act.