Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.
Principal Issues: Will an individual be considered to be enrolled when that individual has accepted a position at a qualifying institution?
Position: Question of fact.
Reasons: An individual will be considered enrolled when the particular designated institution considers the individual to be enrolled.
XXXXXXXXXX 991031
M. P. Sarazin
Attention: XXXXXXXXXX
August 6, 1999
Dear Sirs:
Re: Enrolled for Purposes of a Registered Education Savings Plan (RESP)
This is in reply to your letter dated April 16, 1999, wherein you requested confirmation that a beneficiary under an RESP will be considered enrolled for the purpose of the requirement in paragraph 146.1(2)(g.1) of the Income Tax Act (the "Act"), when the beneficiary has accepted a position at a qualifying institution.
Comments
The Act does not define the term "enrolled" so the ordinary meaning of the word must be used. The Concise Oxford Dictionary states that enroll means:
(1) write name of (person) on list, esp. of army, incorporate (person) as member in society, etc;
(2) enter ones name on a list etc; or
(3) hence enrollment, (esp. number of students in a school etc.).
Since the dictionary definition is of limited use, we asked the University of Ottawa what their position was with respect to when an individual is considered enrolled in a program. They advised us that an individual is considered to be enrolled when the individual has been offered a position in a program, the individual has accepted that position, the individual has made an initial course selection for the program and the individual has had that selection approved. However, they advised us that some universities will only consider a person to be enrolled upon payment of tuition fees.
We have concluded that an individual will be considered enrolled for purposes of the Act when the individual is considered enrolled by the particular designated educational institution. The expression "designated educational institution" has the meaning assigned by subsection 118.6(1) of the Act.
We trust the above comments will be of assistance.
Yours truly,
Patricia Spice
for Director
Financial Industries Division
Income Tax Rulings and
Interpretations Directorate
