1048547 Ontario Inc. v R, 2023 TCC 24, illustrates the evidentiary burden a taxpayer will face when trying to justify travel expenses to exotic locations that seem to have nothing to do with the taxpayer’s ordinary business operations. If you carry on business in North America, but you claim you held a business meeting in Aruba, you cannot just show up in court and assert a business purpose. You will need to produce itineraries, receipts, email messages and meeting agendas. You should be able to identify the effect of the meeting on the business’s plans. If family members attended the meeting, they will need to testify. If you produce no documentation, and key witnesses do not testify, not only will you fail to discharge the evidentiary burden placed on a taxpayer, you will likely have the court draw an adverse inference from the omissions.
