23 February 2004 Internal T.I. 2004-0056061I7 - Bus passes distributed by a church

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.

Principal Issues:

A church organization operates a soup kitchen and shelter for street people. The organization gives bus passes to the street people who volunteer their time at the soup kitchen and shelter. Are the bus passes taxable to the recipients?

Position: No.

Reasons: The purpose of the bus passes is to defray out-of-pocket expenses of the volunteers. By providing the bus passes, the volunteers neither gain nor lose significantly.

		February 23, 2004

	Yvon Racine	HEADQUARTERS
	Business Returns and Payments	Terry Young, CA
	  Processing Directorate	952-1506
	750 Heron Road, 9th Floor
		2004-005606

Bus Passes

We are writing in response to your email of January 13, 2004, concerning the taxability of bus passes provided by a church organization. We also acknowledge our conversations of February 18 and 19.

XXXXXXXXXX (the "Church") operates a soup kitchen and shelter for the homeless. Some of the homeless individuals volunteer at the soup kitchen and shelter. They assist with tasks such as cleanup, maintenance and mail-outs. The duration of the tasks can vary from an hour to a full day. There are no set work schedules. The Church provides monthly bus passes to a number of the volunteers with a value of approximately $XXXXXXXXXX per month or $XXXXXXXXXX per year. Your Section has determined that no employer-employee relationship exists between the Church and the volunteers. You have asked us if the value of the bus passes is taxable and if the Church is required to issue information slips in respect of the benefit.

Based on the information you provided us, the bus passes likely do not constitute social assistance. In our opinion, the better view is that the bus passes are provided to defray the volunteers' out-of-pocket expenses of providing their services free on a voluntary basis. In other words, the recipients neither gain nor lose significantly as a result of getting the bus passes from the Church in return for volunteering their services. Therefore, the provision of the bus passes does not trigger any consequences for the volunteers under the Act and the Church is not required to issue information slips in respect of providing the passes.

We trust our comments will be of assistance to you.

John Oulton, CA
for Director
Business and Partnerships Division
Income Tax Rulings Directorate
Policy and Planning Branch