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: Is income from employment by the United Nations Population Fund exempt from tax in Canada?
Position: The taxpayer is entitled to a deduction in computing his taxable income for the income from employment by the United Nations Population Fund pursuant to subparagraph 110(1)(f)(iii) of the Act.
Reasons: The United Nations Population Fund is an integral part of the United Nations. Therefore, pursuant to paragraph 8900 (1)(a) of the Regulations, it is a prescribed international organization for the purposes of subparagraph 110(1)(f)(iii) of the Act.
XXXXXXXXXX 2006-020023
January 31, 2007
Dear Sir:
Re: Amounts received from the United Nations
This is in reply to your letter of July 20, 2006 in which you requested our opinion concerning the taxation of the amounts that you have received from the United Nations.
In your letter, you indicate that you are a permanent resident in Canada and that you are a staff member of the United Nations Population Fund (UNFPA). Your salary is subject to some deductions by the United Nations.
You are asking whether the salary paid by the United Nations is subject to taxation in Canada or not.
Written confirmation of the income tax implications inherent in particular transactions is given by this Directorate only where the transactions are proposed and are the subject matter of an advance income tax ruling request as describes in Information Circular 70-6R5 dated May 17, 2002 issued by the Canada Revenue Agency. A fee is charged for this service. Although we are unable to provide any comments with respect to your particular fact situation otherwise than in the form of an advance income tax ruling, the following general comments may be of assistance.
Subparagraph 110(1)(f)(iii) of the Income Tax Act (the "Act") provides for a deduction in the computation of the taxable income for any amount that is income from employment with a prescribed international organization. A prescribed international organization is described in subsection 8900(1) of the Income Tax Regulations (the "Regulations"). The United Nations is such a prescribed international organization pursuant to paragraph 8900(1)(a) of the Regulations and each international organization that is a specialized agency brought into relationship with the United Nations in accordance with Article 63 of the Charter of the United Nations is a prescribed international organization pursuant to paragraph 8900(1)(b) of the Regulations.
UNFPA is an integral part of the United Nations being a subsidiary organ of the UN General Assembly. Therefore, pursuant to paragraph 8900(1)(a) of the Regulations, UNFPA is a prescribed international organization for the purposes of subparagraph 110(1)(f)(iii) of the Act.
In preparing your Income Tax and Benefit Return for the year 2006, you will have to report your income from employment from the United Nations as employment income on line 101 of the T1 General and you will be entitled to a deduction for the same amount on line 256 of the T1 General.
We trust the above comments will be of some assistance.
Yours truly,
Alain Godin, Manager
for Director
International and Trusts Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch
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