CRA finds that a provincial professional association did not collect fees from members as agent for the national professional association

A provincial professional association (the “Association”) was itself a member of a national professional association (the “Society”). CRA found that member fees paid to the Association were not exempted under ETA Sched. V, Pt VI, s. 18 since membership in the Association was not required to maintain a professional status recognized by statute. It noted that persons could offer similar services in the province in question without being a member of the Association.

The Association, in turn, paid fees to the Society. Although these fees appeared to be stated in the Society by-laws to be paid “on behalf of” Society members, CRA found that the fees did not represent Society membership fees that the Association was collecting as agent for the Society given that “the bylaws of the [Society] provide no liability to the individual members to pay membership dues to [Society].”

Neal Armstrong. Summaries of 18 October 2017 Ruling 173963r under Sched. V, Pt VI, s. 18 and General Concepts – Agency.