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.
XXXXXXXXXX
XXXXXXXXXX (the "taxpayer")
We are writing with respect to the T2003 of January 15, 1993, from the T1 Adjustments, Assessing Section XXXXXXXXXX in your office, regarding the November 26, 1992, letter from the above noted taxpayer.
As we understand the situation, the taxpayer is concerned about the income tax implications for the amounts he receives from the XXXXXXXXXX (the "school") in return for providing room and board to students from the school.
In a recent telephone conversation with the taxpayer, we advised that:
- since the nature of his enquiry relates to an actual situation that falls within the jurisdiction of the district office, we would be providing our comments to the district office who would reply to his enquiry.
- since the determination requested involves a finding of fact, a binding ruling could not and would not be given.
With respect to his enquiry the taxpayer further advised that:
- he is not employed by the school and only recently became involved in providing room and board to students.
- the services provided are anywhere from one month to five months in duration, for which he receives $125 per week. He has been reporting these amounts as income and has been deducting reasonable expenses incurred in this regard.
- the school apparently received an oral opinion from someone in an unnamed district office indicating that, since he was considered to be a "host family", the amounts were not taxable.
- in the absence of a written opinion to the school, the taxpayer wanted clarification of his income tax position.
OUR COMMENTS
From the limited information submitted by the taxpayer, it appears that the services provided by the taxpayer is an endeavour which generates net income after deducting relevant expenses. Accordingly, it is our opinion that the amounts received could be considered to be income from business and that the taxpayer's procedure of reporting these amounts, net of reasonable expenses should be continued.
The taxpayer's letter along with Forms T702 dated December 16, 1992, and T2003 dated January 15, 1993, are attached.
P.D. Fuoco Section Chief Personal and General Section Business and General Division Rulings Directorate Legislative and Intergovernmental 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, 1993
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, 1993
Email this Content