F.B. Fontaine (613) 957-2140
MAR 3 1988
Dear Sirs:
Re: Professional Membership Dues
This is in reply to your letter dated October 9, 1987, wherein you asked whether or not annual membership dues paid by members of the XXXX would be deductible under subparagraph 8(ll)(i)(i) the Income Tax Act (the "Act").
Paragraph 3 of Interpretation Bulletin, IT-158R states that since it is the employee's professional status (and not that of the organization) that must be recognized by statute, dues are deductible only where membership in an organization is necessary for the employee to retain his professional status.
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it is our view that membership dues paid in a year by a member to the Institute would be deductible in computing the member's income for the year from an office or employment pursuant to subparagraph 8(1)(i)(i) of the Act, to the extent that the dues are applicable to the income. (See paragraph 2 of IT-158R ).
Yours truly,
ORIGINAL SIGNED BY ROBERT H. JOYCE for Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch SMALL BUSINESS AND GENERAL DIVISION