Employed fishing outfitters and guides provide materials, such as salmon flies or filament to repair fishing lines, to clients, to ensure the success of the fishing trip. The collective agreement is silent on whether the employees must incur these expenses. The employees receive remuneration, regardless of whether the client is fishing, and they are reimbursed for equipment expenses up to specified limits. After discussion the potential deduction under s. 8(1)(i)(iii) (as to which the materials might qualify as “supplies”), CRA stated:
Since there is no definition of the term "tradesperson" in the Act, this term should be interpreted in its ordinary meaning and it is our view that fishing guides could be considered as tradespeople.
… [I]t appears that the property described in your letter is not tools. [Per IT-422, para. 2] in order for an asset to be a tool it must be designed to create a physical change in something or to be used as an instrument of measurement or manipulation. Examples are hammers, saws, squares, screwdrivers and hand-held power tools. Therefore, no amount could be deductible by fishing guides by virtue of paragraph 8(1)(s).