Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.
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: Whether payments to Junior "C" hockey players are taxable.
Position: General comments only.
Reasons: Question of fact.
XXXXXXXXXX W. Antle, CGA
2001-007846
June 28, 2001
Dear XXXXXXXXXX:
We are replying to your facsimile dated April 4, 2001, in which you requested our opinion whether payments to players of a Junior "C" hockey team (the "Team") must be reported for income tax purposes. You indicated that you are the executive of this team, and one of the parents of your players has approached you with this question. Some players are given compensation in the form of mileage payments, leased cars, hockey equipment, room and board, and/or cash for educational expenses. Some players are reportedly receiving $150 per game, for a 40 game season, while others have their university tuition paid. This type of compensation is permitted under the XXXXXXXXXX standards, and the players still maintain their amateur status.
The tax treatment of the above amounts is dependant upon whether the hockey players are considered to be employees of the Team. This can only be determined after reviewing all of the facts including the specific arrangements or contracts between the amateur payers and the team. For more information in this regard, please refer to the Canada Customs and Revenue Agency ("CCRA') publication entitled Employee or Self-employed. If you are unable to determine whether the players are employees of the team, you may request a ruling from the Revenue Collections Division of your local tax services office as to whether an employer-employee relationship exists.
For general information on the taxation of various employment-related payments and benefits, please refer to IT-470R (Consolidated) Employees' Fringe Benefits and the 2000 Employer's Guide to Taxable Benefits. With respect to the payment of tuition fees, a portion of the amount may be included in income as a scholarship or bursary where the players are not employees of the team. Please refer to IT-75R3, Scholarships, Fellowships, Bursaries, Prizes, and Research Grants for more information in this regard. The annual $500 exemption referred to in paragraph 1 of this bulletin has been increased to $3,000 for scholarships or bursaries paid in connection with enrollment in a program for which the individual may claim the education tax credit.
The publications mentioned above are available on our website at www.ccar-adrc.gc.ca or at your local tax services office.
We trust that these comments will be of assistance.
Yours truly,
John Oulton, CA
for Director
Business and Partnerships Division
Income Tax Rulings Directorate
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