8 January 2007 External T.I. 2006-0202931E5 - Prescribed Prize

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:

Whether the annual Regional Awards, Minister's Award and Premier's Award for Agri-Food Innovation Excellence are prescribed prizes pursuant to Section 7700 of the Income Tax Regulations.

Position:

Yes.

Reasons:

On the basis of the information provided, we agree that the Prizes qualify as prescribed prizes under section 7700 of the Regulations and therefore, are exempt from income under paragraph 56(1)(n) of the Act.

								2006-020293
XXXXXXXXXX 							D Tiu
(613) 957-8961
January 8, 2007

Dear XXXXXXXXXX:

Re: Prescribed Prize

We are writing in response to your August 25th, 2006 inquiry on the above subject and further to our subsequent telephone discussions (XXXXXXXXXX/Tiu). You inquired whether the annual Regional Awards, Minister's Award and Premier's Award for Agri-Food Innovation Excellence are prescribed prizes pursuant to Section 7700 of the Income Tax Regulations (the "Regulations").

The Awards for Agri-Food-Innovation Excellence ("Prizes") recognize that farmers have always been innovative in the running of their businesses and will foster even greater innovation across the province's agri-food sector. There would be up to 55 regional awards, valued at $5,000 each and from these regional winners, the recipients of the Premier's Award, of up to $100,000, and the Minister's Award, of up to $50,000, will be selected. The Premier's Award and the Minister's Award will be presented at the Premier's 2007 Agri-Food Summit.

Individuals and/or groups representing agri-food businesses and organizations can submit applications. To be eligible, at least one of the applicants must be a farmer. The innovation must have been developed and used on an Ontario farm, and must have the potential for use on a broader basis and have a positive effect on the agriculture industry. The following four broad criteria will be used to identify the winning innovations:

• The uniqueness and originality of the idea;
• The stage of development of the concept;
• The potential for and ease of adoption and/or commercialization of the innovation; and
• The economic and/or social benefits resulting from the innovation to Ontario's agri-food sector.

The August 25th, 2006 news release by the province and the nomination guidebook on the awards program is available in the Ontario Government site at http://www.omafra.gov.on.ca/english/premier_award/index.html.

Section 7700 of the Regulations defines a prescribed prize for the purpose of subparagraph 56(1)(n)(i) of the Income Tax Act (the "Act") as any prize which is recognized by the general public and which is awarded for meritorious achievement in the arts, the sciences or service to the public, but does not include any amount that can reasonably be regarded as having been received as compensation for services rendered or to be rendered. On the basis of the information described above and our review of the information contained in the above noted news release and nomination guidebook, we agree that the Prizes qualify as prescribed prizes under section 7700 of the Regulations and therefore, are exempt from income under paragraph 56(1)(n) of the Act.

We trust this information is helpful.

Yours truly,

Randy Hewlett
Section Manager
For Division Director
Business and Partnerships Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch