Principal Issues: Whether certrain amounts paid to Seminarians to enable them to pursue their studies for the priesthood would represent scholarships or bursaries.
Position: Yes, the Archdiocese of XXXXXXXXXX should be issuing T4A slips to the Seminarians showing the amounts of scholarships or bursaries paid.
Reasons: Paragraph 56(1)(n) of the Income Tax Act (the "Act") provides that "there shall be included in computing the income of a taxpayer " the total of all amounts ... received by the taxpayer ... as or on account of a scholarship, fellowship or bursary" which exceeds the taxpayer's scholarship exemption computed under subsection 56(3) of the Act. Based on the definition of "scholarships and bursaries" contained at paragraph 6 of Interpretation Bulletin, IT-75R4, it is our view that the above amounts received by the Seminarians to enable them to pursue their studies for the priesthood would represent scholarships or bursaries within the meaning of paragraph 56(1)(n) of the Act.
Paragraph 47 of IT-75R4 states that "Under subsection 200(2) of the Regulations, every payer of a research grant, scholarship, fellowship, bursary or prize (other than a prescribed prize) must report the amount on a T4A Statement of Pension, Retirement, Annuity and Other Income". Accordingly, it is our view that the Archdiocese of XXXXXXXXXX should be issuing T4A slips to the Seminarians showing the amounts of scholarships or bursaries paid.