25 February 1991 Income Tax Severed Letter

19(1)                    910498
                                             S. Short
                                             (613) 957-2134

February 25, 1991

                    19(1)Re:  Convention Expenses

Thank you for your letter of February 8, 1991. Your enquiry has been referred to our office for reply by the Penticton District Office. You have queried the deductibility of convention expenses to be incurred by

                    24(1)

The deductibility for income tax purposes of convention expenses depends upon each individual's particular set of circumstances and can be determined only after his or her income tax return is filed and all relevant facts determined. However, we do offer the following comments of a general nature which may be of assistance to you.

Subsection 20(10) of the Income Tax Act permits a deduction in respect of expenses incurred in attending not more than two conventions per year for taxpayers who are carrying on a business. The enclosed Interpretation Bulletin IT-131R2 should provide you with written details of much of the information relayed to you verbally by the Penticton District Office and addresses your concerns about physicians that may attend from other areas of Canada. You will note, for example, that different rules apply to self-employed individuals than apply to employees.

We trust our comments and the enclosed information are of assistance to you.

Yours truly,

for Director Business and General Division Rulings Directorate legislative and Intergovernmental Affairs Branch

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