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.
July 15, 1993
| SURREY TAXATION CENTRE |
HEAD OFFICE |
| Personal and General Taxpayer Services Division |
| Section 1233 334-33 |
A. Humenuk (613) 957-2134 |
Attention: Pam Lyons
XXXXXXXXXX
Self Employment Assistance Program
We are replying to your memorandum of January 28, 1993 concerning the above noted taxpayer and the amounts he received from Employment and Immigration Canada under the Self Employment Incentive Program (SEI).
We apologize for the delay in response which was necessitated by the need for further information about the program. We have discussed the matter with XXXXXXXXXX the writer of the letter, and he is aware of the delay. At the time of our last discussion, he had not yet obtained the appointment of the executor and could thus not provide us with the appropriate authorization.
You have asked whether the $XXXXXXXXXX received from Employment and Immigration Canada under SEI in 1989 is required to be included in XXXXXXXXXX income.
SEI was originally set up under the Community Futures Program to enable certain unemployed workers to become self-employed by providing grants for a living allowance while their businesses are being established. The program was available to individuals entitled to receive unemployment insurance benefits as well as individuals receiving social assistance. Eligibility for the grant was based primarily on need rather than the potential for success of the particular business. The program was reintroduced in May 1992 as the Self Employment Assistance Component; while the method of delivering the assistance has changed in some respects (individuals entitled to UI benefits will continue to receive UI benefits) the purpose and scope of the program remain unchanged.
In accordance with the comments contained in paragraph 2 of IT-273R, it is our view the grant or allowance should be treated as business income to the recipient. Benefits received as unemployment insurance benefits however, will continue to be taxed under subparagraph 56(1)(a)(iv) of the Act.
We are returning XXXXXXXXXX 1989 income tax return.
P.D. Fuoco Section Chief Personal and General SectionBusiness and General DivisionRulings DirectorateLegislative 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