Principal Issues: (1) Whether a T4A slip is to be issued in the taxation year in which a bursary is awarded or when the bursary is credited to a student's account in a scenario where an educational institution awards a bursary to a student in 2009 but instead of being received by the student, the educational institution credits the student's account against future tuition? (2) Whether a third party that funds the bursary is responsible for issuing the T4A slip or whether it is the responsibility of the educational institution that awards the bursary?
Position: (1) Provided that no conditions are placed in relation to the use of the bursary when it is awarded in 2009, the student will be considered to have constructively received the amount in 2009 and the T4A slip will need to be issued by the end of February 2010 for the 2009 taxation year. Otherwise, the T4A slip will need to be issued in the taxation year in which the amount is used towards the student's tuition. (2) The educational institution could issue the T4A slip as agent on behalf of the non-profit. Otherwise, the non-profit organization will be required to issue the T4A slip.
Reasons: (1) Doctrine of constructive receipt (2) Pursuant to subsection 200(2) of the Income Tax Regulations, every payer of a research grant, scholarship, fellowship, bursary or prize must report the amount on a T4A slip. There is no exclusion to prohibit the educational institution to act as agent of the non-profit organization to issue the T4A.