| 19(1) | File No. 900555 |
| J.D. Jones | |
| (613) 957-2104 |
June 26, 1990
19(1)
Re: Medical Boarding Payments
This is in reply to your letter of April 27, 1990, wherein you requested our opinion on the income tax treatment of payments received by an individual for providing accommodation and meals (medical boarding) to patients travelling to receive medical care.
As we understand the situation, the Government of the Northwest Territories frequently transports patients from small settlements to larger urban centres for the purpose of receiving medical care. In some cases, these patients are admitted to hospital. In other cases, they have appointments for consultations or diagnostic treatment procedures on an out-patient basis.
In the latter case, a patient may be placed in a private home for accommodation and meals. The individual homeowner is paid a small per diem allowance ($33.00 or $36.30 for areas in the far north due to increased costs) from the Department of Health for the services provided to the medical boarders. The length of stay varies from overnight to a week or two and, in a few exceptional circumstances, for several months.
You wish to know if the above payments would be considered to be income in the hands of the individual homeowner.
Based on the above information, it is our view that payments as described above to an individual homeowner must be included in income only if the individual is carrying on a business of providing these facilities with a view to earning a profit therefrom.
We hope that our comments will be of assistance to you. If you have any further questions concerning this matter, please do not hesitate to contact us.
Yours truly,
for Director Business and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch