5-8450
J.D. Jones
(613)957-2104
19(1)Re: Employment Expense
This is in reply to your letter of July 21, 1989 wherein you requested a written ruling with respect to the deductibility of the cost of acquiring a cellular telephone from employment income.
We are unable to provide the requested ruling as advance income tax rulings are given only in respect of proposed transactions and only when presented in the format set out in Information Circular IC 70-6R (copy enclosed). We wish to point out that the fee for this service has changed; charges are at the rate of $65 per hour with a deposit of $325 to accompany the original request.
Nevertheless, we offer our opinion on the deductibility from employment income of the cost of acquiring a cellular telephone of an employee in the performance of the duties of his/her office or employment, no deduction in respect of this expense may be claimed for tax purposes.
We enclose a copy of the Department's 1988 Employment Expenses Tax Guide which deals with the type of expenses which may be deducted from employment income.
Yours truly,
for Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch