10 March 1993 Internal T.I. 9304327 F - Indians - Training Allowances

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.

March 10, 1993

Training Allowances et al - Status Indians

This is in reply to your Fax of February 10, 1993 asking that we advise if training allowances, living away from home allowances, travel allowances and dependant allowances, paid to status Indians by CEIC under a program for XXXXXXXXXX are taxable or non-taxable when received.

On page 6 of the December 30, 1992 memorandum from the Taxation Programs Branch it states that training allowances received by a status Indian are exempt if:

the Indian qualified for the training allowance through employment, the income from which was tax exempt; or

the training allowance is paid by a government, and the Indian either lives on a reserve, or takes the training on a reserve.

We assume from your comments about "returning to the reserve" that the participants are resident on the reserve and the training allowance is paid by the federal government (CEIC). On the assumption that all participants meet the above criteria, the training allowance when received would be exempt. As the other listed allowances are received in connection with the training allowances,and are, in a sense, themselves training allowances, they are exempt as well, providing of course, the recipient receives the training allowance as exempt income.

We trust this is the information you require.

E. Wheeler for Director Business and General Division Rulings Directorate Legislative and Intergovernmental Affairs Branch

c.c.      Rick Owen