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: 1. Whether a post-doctoral fellowship is exempt from tax.
Position: 1. Generally, no.
Reasons: 1. In our view, post-doctoral fellows receive either employment income or research grants.
January 5, 2011
Dear XXXXXXXXXX :
Re: Income Tax Treatment of Post-Doctoral Fellows
This is in response to your e-mail dated January 5, 2009, in which you asked whether the income you received in connection with your position as a post-doctoral fellow qualifies as fully exempt scholarship income for income tax purposes, and if the amount is tax exempt, are you required to complete a form TD1, Personal Tax Credits Return.
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 submitted in the manner set out in Information Circular 70-6R5, Advance Income Tax Rulings. Where the particular transactions are completed, the inquiry should be addressed to the relevant Tax Services Office. However, we are prepared to offer the following comments.
The nature of the income received by any individual must be determined on a case-by-case basis taking into account all of the relevant facts of the individual's situation. Generally, the CRA does not consider post-doctoral fellows to be "students" as that term is used in the Income Tax Act (ITA). For the purpose of the ITA, the CRA has consistently viewed post-doctoral fellows as being similar to other individuals who are required to undertake a period of paid training after completing their studies but prior to pursuing an independent professional career. As with the compensation received by these other professionals (for example, doctors, lawyers, and accountants), the compensation received by post-doctoral fellows is generally taxable. Please find attached a copy of Rulings document E2009-031190 which discuses the issue in greater detail.
Your employer or payer is responsible for deducting income tax from your remuneration. Individuals who will receive salary, wages, commissions, employment insurance benefits, pensions, or other remuneration must complete a federal Form TD1 and, if more than the basic personal amount is claimed, a provincial or territorial Form TD1.
We trust the above comments are of assistance.
for Acting Director
Ontario Corporate Tax Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch
All rights reserved. Permission is granted to electronically copy and to print in hard copy for internal use only. No part of this information may be reproduced, modified, transmitted or redistributed in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, or stored in a retrieval system for any purpose other than noted above (including sales), without prior written permission of Canada Revenue Agency, Ottawa, Ontario K1A 0L5
© Her Majesty the Queen in Right of Canada, 2011
Tous droits réservés. Il est permis de copier sous forme électronique ou d'imprimer pour un usage interne seulement. Toutefois, il est interdit de reproduire, de modifier, de transmettre ou de redistributer de l'information, sous quelque forme ou par quelque moyen que ce soit, de facon électronique, méchanique, photocopies ou autre, ou par stockage dans des systèmes d'extraction ou pour tout usage autre que ceux susmentionnés (incluant pour fin commerciale), sans l'autorisation écrite préalable de l'Agence du revenu du Canada, Ottawa, Ontario K1A 0L5.
© Sa Majesté la Reine du Chef du Canada, 2011