25 July 2000 External T.I. 2000-0032585 - RESEARCH GRAT-TRAVELLING EXPENSES

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.

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

Principal Issues: An individual, who received a research grant, will carry out research in Scotland. As a result of the nature of the work, a research assistant is required for safety reasons. We have been asked whether the individual is entitled to deduct the assistant's airfare ($XXXXXXXXXX ) and certain other costs (food and accommodation) in respect of the assistant.

Position: NO

Reasons: Pursuant to comments in paragraph 31 of IT-75R3, the individual is not entitled to deduct the expenses.

XXXXXXXXXX 2000-003258
M. Eisner
(613) 957-2138
July 25, 2000

Dear XXXXXXXXXX:

Re: Research Grant - Deduction of Expenses for Assistant

This is in reply to your letter of June 16, 2000 concerning the above-noted subject.

You have indicated that you are currently enrolled at XXXXXXXXXX. As part of your research, you are carrying out a study of XXXXXXXXXX in Scotland this coming summer (XXXXXXXXXX). For the purposes of carrying out your research, you have received research grants.

You have indicated that as a result of the nature of the work, you are required to have a field assistant for safety reasons. Your advisor has employed the assistant for the duration of the study.

In claiming expenses against the research grants, you have asked whether you are entitled to deduct your assistant's airfare ($XXXXXXXXXX) and certain other costs in respect of your assistant (food, meals, accommodation).

Our Comments

In order to determine the tax consequences in respect of research grants, it would be necessary to review all the relevant facts and documentation. However, based on the information provided to us and on the assumption you are entitled to deduct travelling expenses pursuant to comments in paragraph 31 of Interpretation Bulletin IT-75R3 "Scholarships, Fellowships, Bursaries, Prizes, and Research Grants" in connection with the time period while you are in Scotland, we are providing you with the following comments.

As you have indicated, it is the position of this Agency that an individual may not claim the travelling expenses of his or her spouse and children or other third parties. The basis of this position is the decision of the Tax Court of Canada in Subbarao v. M.N.R., (86 DTC 1554). In our view, your assistant would be covered by the comments in paragraph 32 of IT-75R3, with the result that you would not be entitled to claim her airfare and the other costs described above.

We trust that our comments are of assistance to you.

Yours truly,

John Oulton
for Director
Business and Publications Division
Income Tax Rulings
Policy and Legislation Branch

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