Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CCRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ADRC.
Principal Issues: When to complete T4A's for the payment of certain fellowships that are taxable to the recipients under paragraph 56(1)(o) of the Income Tax Act. That it, whether the payments should be reported on T4A's when paid or based on the period the payment relates to.
Position: When paid.
Reasons: Paragraph 200(2)(b) of the Income Tax Regulations.
XXXXXXXXXX 2002-014915
J. Gibbons, CGA
September 25, 2002
Dear XXXXXXXXXX:
We are replying to your letter dated June 25, 2002, concerning XXXXXXXXXX obligation to complete T4A's for the payment of certain XXXXXXXXXX Fellowships that are taxable to the recipients under paragraph 56(1)(o) of the Income Tax Act. XXXXXXXXXX. Your particular concern is whether the payments should be reported by XXXXXXXXXX on T4A's in 2002 (i.e., when paid), or 2003 (i.e., the period it relates to).
The requirement to complete a T4A for the payment of a grant to carry on research is found in paragraph 200(2)(b) of the Income Tax Regulations. Pursuant to this provision, a payer must complete a T4A when such a grant is paid.
It should be noted that the completion of the T4A by XXXXXXXXXX coincides with the reporting of the payments by the recipient. That is, under paragraph 56(1)(o), the recipients are required to include particular grants in income in the year in which they are received.
We trust that these comments will be of assistance.
Yours truly,
Daryl Boychuk, LLB
for Director
Business and Partnerships Division
Income Tax Rulings Directorate
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