CTF - 1990 Conference Report
QUESTION I-8
REIMBURSEMENT OF LEGAL EXPENSES
New paragraph 6(1)(j) requires that, for amounts received after 1989, an award or reimbursement of legal expenses of a taxpayer, which were incurred to collect salary and wages and which are/were deductible to the taxpayer under paragraph 8(1)(b) of the Act, must be included in income.
What is Revenue Canada's position with respect to the reimbursement of such legal expenses received before 1990?
DEPARTMENT'S POSITION
As stated in paragraph 14 of Interpretation Bulletin IT-99R3 "Legal and Accounting Fees", an award or reimbursement received in respect of legal fees incurred to collect salary or wages will reduce the amount of any deduction allowed under paragraph 8(1)(b) of the Income Tax Act.
CTFNovember 1990Annemarie HumenukSection 24