19 December 2007 External T.I. 2007-0248001E5 - BC Training Tax Credit

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 British Columbia Provincial Training Tax Credit (BC TTC) provided to an apprentice (individual) is to be included in the taxable income of an apprentice for purposes of the Income Tax Act (Canada) and the Income Tax Act (British Columbia).

Position: No.

Reasons: The fact that the apprentice need not be employed to be eligible for the credit suggests the credit does not have employment as its source and thus would not be taxable under section 6 of the Income Tax Act (Canada)

								2007-024800
XXXXXXXXXX 							Joy Bertram,
B. Comm.,CGA, CPA (vt)
(613) 957-8954
December 19, 2007

Dear XXXXXXXXXX ,

Re: British Columbia Training Tax Credit ("TTC")

This is in response to your letter of July 27, 2007 requesting our opinion as to whether the TTC provided to an individual apprentice is to be included in the taxable income of an apprentice for purposes of the federal Income Tax Act (the "Act") and the British Columbia Income Tax Act (the "Provincial Act").

We understand that new Part 9 of the Provincial Act has been enacted to provide a refundable provincial tax credit to sponsored apprentices who are registered in and complete specified levels of an eligible recognized apprenticeship program, as designated by regulation. We note that entitlement to the TTC is not contingent upon being employed and in fact may be available in circumstances in which the apprentice is not an employee. An apprentice's sponsor may be an employer, a trade union or a board.

We confirm that the TTC will not be included in the taxable income of recipient apprentices.

We trust that these comments will be of assistance.

Yours truly,

Renée Shields
for Director
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch