Can you claim the Criminal Records Check and Child Abuse Registry Check as Professional Dues when required for employment and paid by the employee?

New for 2019, the College of Registered Nurses in Manitoba (CRNM) is now phasing in the requirement that nurses complete the Child Abuse Registry Checks and the Criminal Records Check at their own cost.  These will be required every five years, and will apply to a limited number of nurses for their 2020 Practicing License, which is paid in November 2019.  The selected nurses will not be issued their nursing license without these registry checks.  We already claim Nursing License Fees to the CRNM and also Insurance Fees as Professional Fees on Line 212.  Has anyone claimed the Child Abuse Registry Checks and Criminal Records Checks as Professional Dues on Line 212 since these are now being required for employment and paid for by the employee.  Would it be better to acquire a T2200 form from the employer to claim these expenses as Employment Expenses on Line 229?  I'm not sure how agreeable the CRNM will be with providing T2200 forms to all the nurses in Manitoba once these requirements are fully implemented. Thought I would post the question here before phoning CRA to discuss.


I phoned CRA General Inquiries line and discussed this scenario with an agent.  
From his perspective, this agent agreed that Criminal Record Checks & Child Abuse Registry Checks would fall under the criteria of Professional Dues when paid for by the client.
He agreed that this was a better fit vs claiming them on Line 229 (Employment Expenses) which would then require the association to complete T2200 forms to all nurses in Manitoba in order to claim these expenses.


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