22 January 1991 Income Tax Severed Letter

January 22, 1991

Assessing and Enquiries                 Business and General
  Directorate                             Division
                                        S. Short
                                        957-2134
Ms. P. McNally
Director

                                        903203

Professional Membership Dues - Paragraph 8(1)(i) of the Act

The determination of whether the payment of professional membership fees by an employer in respect of an employee is a taxable benefit to the employee depends upon who is the primary beneficiary of the payment. In cases where such fees are treated as a taxable benefit to an employee, we would like to state that, administratively, the fees are deductible to the employee if they otherwise qualify under paragraph 8(1)(i) of the Act.

We seek your agreement on this position.

B. W. Dath Director Business and General Division Rulings Directorate

000324