| 913147 | |
| R.B. Day | |
| (613) 957-2136 |
19(1)
January 15, 1992
Dear 19(1):
We are writing in reply to your letter of November 4, 1991, wherein you requested our opinion as to whether or not air fare to Arizona, for a taxpayer and/or his nurse/companion would be an allowable medical expense for the purposes of either of paragraphs 118.2(2)(g) or (h) of the Income Tax Act (the Act).
As we understand it, one of your clients has what you refer to as a "'marked' physical impairment". The taxpayer's condition is made more comfortable by the presence of a warm and dry climate. Canadian winters do not provide this type of climate. The taxpayer also requires the assistance of a nurse/companion. The taxpayer believes that the air fare is an allowable medical expense because the Arizona climate offers a "medical service" unavailable in Canada.
Our Comments
We are unable to agree with your client's views in this regard.
The relevant provisions in the Act were enacted to permit the deduction of reasonable travel costs incurred by taxpayers, such as those situated in rural or remote areas, to enable them to obtain medical services in more populous areas that are not available in their particular locale. For purposes of the Act "medical services" relate to services provided by various health professionals and related institutions.
In view of the forgoing, it is our opinion that a warm dry climate, such as that found in Arizona or other similar regions, does not provide a medical service as envisioned by the Act. The costs of air fare as described above would not, therefore, be a qualifying medical expense under any of the provisions in subsection 118.2(2) of the Act.
We trust our comments will be of assistance to you.
Yours truly,
J. Szeszyckifor DirectorBusiness and General DivisionRulings DirectorateLegislative and IntergovernmentalAffairs Branch