J.D. Jones 19(1) 613 957-2104
Dear Sirs:
Re: 80% Food and Entertainment Expense Limitation
This is in reply to your letter of December 14, 1988, wherein you requested a technical interpretation with respect to subsection 67.1(1) of the Income Tax Act (the "Act"). We apologize for the delay in replying.
The type of situations to which the exclusion in paragraph 67.1(2)(e) of the Act was intended to apply are mentioned in the June, 1988 "Explanatory Notes to Legislation Relating to Income Tax" issued by the Minister of Finance. The Department's general position on the subject is now set out in Interpretation Bulletin IT-518 dated March 28, 1989. At this time we are unable to provide you with a definitive reply with respect to the specific situations raised in your letter.
We will review the matter further and make the Department of Finance aware of the points you have raised. We regret that we are unable to be of greater assistance at this time.
Yours truly,
for Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch