6 August 1991 Income Tax Severed Letter

24(1)                         911548
                                                       M. Eisner
                                                       957-2138

Attention:
                         19(1)

August 6, 1991

Dear Sirs:

This is in reply to your letter of May 25, 1991 in which you requested our views on whether or not expenses paid for a child's attendance at a day camp are subject to the limitations ($60 per week or $120 per week, as the case may be) in subparagraph 63(3)(a) (iii) of the Income Tax Act (the Act).

It is the Department's position that expenses paid for a child's attendance at a day camp are not regarded as having been made to a "boarding school or camp" for the purposes of subparagraph 63(3)(a)(iii) of the Act. Accordingly, such expenses would not be subject to the limitations set out therein. For your further information, we are mentioning that this position is consistent with comments in paragraph 4(a) of Interpretation Bulletin IT-495R entitled "Child Care Expenses".

We trust that these comments will be of assistance to you.

Yours truly,

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

                                                       .../cont'd

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