Chapter History S2-F2-C1, Employee Professional Membership and Other Dues
Introduction
The purpose of a Chapter History page is to highlight any amendments to the information contained in a chapter of an income tax folio, including amendments to the information originally contained in an interpretation bulletin that has been cancelled and replaced with a folio chapter. It outlines amendments that have been made as a result of legislative changes and proposed legislative changes, precedential court decisions, as well as new or revised interpretations of the Canada Revenue Agency (CRA).
Except as otherwise noted, all statutory references herein are references to provisions of the Income Tax Act, R.S.C., 1985, c.1 (5th Supp.), as amended and all references to a Regulation are to the Income Tax Regulations, C.R.C., c.945, as amended.
Update July 15, 2025
General
Income Tax Folio S2-F2-C1, Employee Professional Membership and Other Dues, replaces and cancels Interpretation Bulletin IT‑158R2, Employees’ professional membership dues.
In addition to consolidating the content of the former interpretation bulletin, general revisions have been made to improve readability. Any substantive technical and interpretive changes to the information outlined in the former interpretation bulletin are described below.
Legislative and other changes
¶1.1 has been added to note the general limitation under subsection 8(2) that provides that no deductions are allowed in computing income from an office or employment except as specifically permitted under section 8. The definitions of various terms, including office, have also been added, as these terms are used throughout the Chapter and section 8.
¶1.2 (formerly included in ¶1 of IT‑158R2) has been revised to reflect the legislative amendment made to the portion of paragraph 8(1)(i) before subparagraph (i) by 2013, c. 34, s. 172(2), in force June 26, 2013. The amendment expanded the deduction available under subparagraphs 8(1)(i)(i) to (vii) to include amounts paid on behalf of a taxpayer in the year if the amount paid on behalf of the taxpayer was required to be included in their income for the year. The recognition of professional status (formerly discussed in ¶1(c) of IT‑158R2) has been expanded to include territorial statutes. Reference to the reasonableness of annual professional membership dues is added in e) of ¶1.2, based on the general limitation under section 67.
¶1.3 to 1.5 have been added to discuss the meaning of the phrase membership dues and the requirement that membership dues be annual dues. They also discuss the types of payments that will not be considered membership dues or dues paid on an annual basis for purposes of subparagraph 8(1)(i)(i).
¶1.6 has been added to describe the general circumstances under which an employee would likely be considered to have a professional status for purposes of subparagraph 8(1)(i)(i).
¶1.7 to 1.10 have been added to provide information relevant in determining whether an employee’s professional status is recognized by statute for purposes of subparagraph 8(1)(i)(i).
¶1.11 (formerly included in ¶3 of IT‑158R2) has been expanded to note additional factors relevant in determining whether the payment of annual dues is necessary to maintain a professional status.
¶1.15 (formerly included in ¶3 of IT‑158R2) includes the new Example 1 to demonstrate the deductibility of dues paid to maintain professional status.
¶1.16 (formerly included in ¶2 of IT-158R2) includes the new Example 2 to illustrate the circumstances under which professional membership dues are considered to reasonably relate to the employment income source.
¶1.17 (formerly included in ¶6 of IT‑158R2) has been expanded to introduce the discussion of subparagraphs 8(1)(i)(iv), (v), (vi), and (vii), which provide for the deduction of certain other dues from employment income.
¶1.18 and 1.19 (formerly included in ¶6 of IT‑158R2) have been expanded to provide additional information regarding the deduction available under subparagraphs 8(1)(i)(iv) and 8(1)(i)(v).
¶1.20 has been added to briefly describe the deduction available under subparagraph 8(1)(i)(vi).
¶1.21 has been added to describe the deduction available under subparagraph 8(1)(i)(vii). This provision was introduced by 1998, c. 19, s. 69(1), applicable to the 1996 and subsequent tax years.
¶1.22 (formerly included in ¶8 of IT‑158R2) has been revised to remove the reference to tuition fees under paragraph 60(f) for 1987 and prior years. As well, the legislative reference to section 118.5 has been removed and replaced with a reference to Income Tax Folio S1‑F2‑C2, Tuition Tax Credit, for readers seeking additional information.
¶1.24 has been added to describe dues not deductible under paragraph 8(5)(c).
¶1.25 has been added to note that an employee may be eligible to apply for a GST/HST rebate with respect to professional dues paid.