For starters, for a health professional to claim travel from home to the hospital, clinic, or the professional’s practising office, the taxpayer must have a home office. Whether the home office is considered the taxpayer’s regular place of work or principal place of business is a question of fact. The CRA may take the position that a health professional’s principal place of business is where they report to daily and generate their revenues. Most often, this is the place where the professional meets their patients. On the other hand, the courts have suggested that a taxpayer’s principal place of business may instead be where they undertake administrative duties (e.g., bookkeeping, billing, reconciling cash receipts, etc.), charting or documenting on patients, or self-study and research. This is especially true if they have no designated physical space to carry out these activities at the hospital, clinic, or practising office. Given this alternative view on the professional’s principal place of business, it is quite probable that some, but not necessarily all, health professionals could take the position that a home office is their principal place of business and therefore the travel between home and the hospital, clinic or practising office could be considered business use. Health professionals wishing to take such a position should speak to their tax advisors.
Provided that all the requirements have been met, the types of automobile operating expenses that can be deducted include:
In addition, capital cost allowance (i.e., a tax proxy for depreciation), lease costs (of up to $900 + GST/HST per month for leases entered after January 1, 2022, and $800 + GST/HST per month for leases entered before), and interest (up to $300 per month) can be deducted.
It is important to note that these expenses must be allocated between personal and business use, with only the business portion being deductible. The method of allocation is calculated based on the distance travelled for each purpose. As such, the best evidence to support the business use of the vehicle is to keep a business travel logbook including the following information:
Two relatively recent court cases not determined in favour of the taxpayers, reinforce the importance of maintaining a logbook. In Cossette v. QRA, the self-employed taxpayer used his vehicle for business use when visiting his customers. The taxpayer claimed 93 per cent of his automobile expenses as a deduction in his tax return. The court agreed with the Minister’s position that the automobile expenses needed to be substantiated through a reasonable source of documentation to prove the proportionate use of his motor vehicle for business purposes. The taxpayer was unable to provide a logbook and instead, attempted to estimate the amount of usage for business purposes after the fact, based on an estimation of mileage travelled to his customers throughout the year. The court did not accept his unsubstantiated business use percentage and decreased his automobile expense claim significantly. Similarly, in Quraishi et al vs. HMQ, the taxpayer failed to keep a logbook to substantiate his automobile business usage and was unable to refute the Minister’s reassessed claim.
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