9 July 2002 External T.I. 2002-0138865 - RELIGIOUS ORDER

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 CCRA.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ADRC.

Principal Issues:

Whether an organization is a religious order?

POSITION TAKEN:

Relevant documentation should be submitted to the TSO for their determination.

REASONS FOR POSITION TAKEN:

Completed and ongoing transactions are the responsibility of the TSO..

XXXXXXXXXX 						2002-013886
C. Tremblay, CMA
July 9, 2002

Dear XXXXXXXXXX:

Re: XXXXXXXXXX

This is in reply to your letter of May 2, 2002, wherein you request a ruling on the religious status of the organization named above.

We refer you to paragraphs 8, 9, 10, and 11 of Interpretation Bulletin IT-141R (Consolidated), which discusses a religious order. In order to be considered a religious order, the six criteria indicative of a religious order discussed in paragraph 9 of the Bulletin must be met. It is important that the purpose of the organization be primarily religious.

Responsibility for the determination of the implications of completed transactions rests with the relevant tax services office. Accordingly, we suggest that you contact the XXXXXXXXXX Taxation Services Office and supply them with copies of the objects, aims and mandate of the organization in order for them to make the determination as to the religious status of XXXXXXXXXX.

We trust our comments are of assistance,

Yours truly,

Steve Tevlin,
for Director
Financial Industries Division
Income Tax Rulings Directorate
Policy and Legislation Branch