We noticed theserecentitems regarding the U.S. IRS denial of a
100% deduction by the NHL Boston Bruins hockey club in respect of
the team's provision of meals to employees during road
In Canada, section 67.1 of the Income Tax
Act limits the deduction of meals and entertainment to
50% of the lesser of the actual cost or a reasonable amount. There
are several exceptions to this general rule (see subsection
67.1(2)), including exceptions for meals provided in the ordinary
course of a business of providing meals and entertainment for
compensation, fund-raising events, meal costs billed directly to a
client, meals provided to employees at remote work locations, or
holiday parties. If an exception applies, the taxpayer may deduct
100% of the cost.
We are reminded of the Canadian case of Pink Elephant Inc. v. The Queen (2011 TCC
396), in which the taxpayer was successful in establishing that
the exception for meals provided in the course of a business of
providing meals for compensation applied in respect of the
taxpayer's provision of meals during its information technology
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