Words and Phrases - "volunteer"
7 July 2009 External T.I. 2008-0267941E5 F - Pompiers volontaires
Before going on to infer a broader meaning of “volunteer” in the context of s. 81(4), CRA indicated that normally, a “volunteer” (i.e., someone who would not receive any benefits from the municipality as employment or business income) would references the situation where any consideration paid “does not adequately reflect the amount of work performed nor the quality of the services provided (whereas “where the amount of remuneration paid … is sufficient to influence their involvement or participation, it is very likely that the remuneration is taxable as employment income or income from a business”).
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 81 - Subsection 81(4) | “volunteer” in s. 81(4) references its broader meaning under provincial standards legislation, and is initially applied by the employer municipality | 253 |
27 January 2012 External T.I. 2011-0421551E5 F - Pompiers volontaires
Before addressing the volunteer firefighter tax credit, CRA addressed whether amounts received by a part-time firefighter with modest remuneration might be exempt on general principles, stating:
Generally, a volunteer is defined as someone who does something without being remunerated and without being required to do so. In that situation, the volunteer is involved willingly and for the satisfaction of serving his or her community. As a result, it is quite common for a volunteer to be neither an employee nor a contractor serving an organization.
However, many volunteer acts are no longer done entirely without remuneration. Some volunteers receive modest amounts of money, gift certificates, goods or services as compensation. Those payments are not very representative of the amount of work done or the quality of the services rendered.
They are not in themselves real motivators for volunteers to get involved and do not reflect the fair market value of services rendered. Therefore, those payments are not taxable.
However, the volunteer firefighters to which we were referred are not necessarily volunteers as defined above. If that had been the case, the $1,000 exemption and the volunteer firefighter tax credit would be meaningless as they only apply to taxable income.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.06 - Subsection 118.06(1) | “volunteer” firefighters are not true volunteers | 195 |
15 August 2012 External T.I. 2012-0444461E5 F - Pompiers volontaires
In finding that firefighters in a particular town were not entitled to the credit, CRA stated:
If the amounts paid represent only a small amount for the services rendered compared to what it would have cost under the same circumstances to have the same work performed by a regular full-time or part-time employee, we will generally consider the firefighter to be acting as a volunteer.
In the event that, without being equivalent, the hourly rate of a volunteer firefighter is comparable to that of a regular firefighter, we are of the view that the amount paid would not be considered "minimal". As a result, the firefighter in this situation would not be considered to be acting as a volunteer for the purposes of subsection 81(4) and section 118.06.
In considering the definition of the word "volunteer" [bénévole] in Le nouveau Petit Robert de la langue française 2009 dictionary, we are of the view that the firefighter must also act without obligation in order to be considered as a volunteer firefighter for the purposes of paragraph 81(4) and section 118.06.
Thus, an individual who is required to work a minimum number of hours in a given period of time, except for a very limited number of hours, is generally not considered to be a volunteer firefighter for the purposes of subsection 81(4) and section 118.06.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 81 - Subsection 81(4) | “volunteer firefighter” has the same meaning as in s. 118.96(1) | 202 |
12 February 2015 External T.I. 2014-0550771E5 F - Allocation à des bénévoles - chantier particulier
A registered charity sends volunteers on missions to developing countries and pays them an allowance of $X per day. After finding that "remuneration that is quite unrepresentative of the services rendered would not be taxable," CRA turned to a question as to whether the charity could issue donation receipts in accordance with CPC-012 if the volunteers declined the allowance, and stated (TaxInterpretations translation):
[S]uch policy applies only to reimbursement of expenses incurred by the volunteers for the account of the charitable organization and not to allowances which are paid to them.
See summary under s. 5(1).
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 3 - Paragraph 3(a) - Business Source/Reasonable Expectation of Profit | modest compensation to volunteers qua independent contractors not income | 106 |
| Tax Topics - Income Tax Act - Section 5 - Subsection 5(1) | quite unrepresentative remuneration: exempt | 106 |
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(6) | mission work under 2 years in LDCs | 109 |