CRA indicates that an entity may be an eligible entity for CEWS purposes if it is not a public institution

In response to a question as to whether an “organization” that was an inter-municipal authority held by four regional Quebec county municipalities was eligible for the Canada emergency wage subsidy, CRA indicated that an “entity may be an ‘eligible entity’ for CEWS purposes, provided that it is not a ‘public institution,’.” Although the definition of “eligible entity” only explicitly excludes corporations, trusts, registered charities and organizations listed in ss. 149(1)(e), (j), (k) or (l) that are public institutions, this answer seems to indicate that CRA was indifferent as to whether this organization might instead be some other type of association or body.

CRA went on to indicate that regional Quebec county municipalities are municipalities (and, thus, public institutions), but did not address the nature of the authority that they jointly held.

Neal Armstrong. Summary of 23 June 2020 External T.I. 2020-0848441E5 F under s. 149(1)(c) and s. 125.7(1) – eligible entity.