Regulation 237

Subsection 237(2)

Administrative Policy

12 November 2013 Internal T.I. 2013-0497611I7 F - Feuillet T1204

T1204 disclosure applicable only where contract with federal supplier and includes travel reimbursements as “services” consideration

Should reimbursements for travel expenses of external consultants to a federal agency be included on the T1204 form? The Directorate responded:

[I]t is imperative to validate that the amount was paid or reimbursed under a services contract … . [I]f the relationship between the federal agency and the recipient of a payment is not contractual in nature, the form does not have to be filed.

…The term service generally refers to manual or intellectual work that has a certain value in the eyes of a customer. In our view, if to provide the service, the supplier must travel, the latter would be part of the service and would be included on the T1204 form.

...[A]ssuming that a contractual relationship exists between the consultants and the federal agency payer … reimbursements for travel expenses should be disclosed on the T1204 form.

Words and Phrases

15 July 2008 External T.I. 2008-0278971E5 F - Feuillet T1204

no T2014 slips required where the recipients did not have a contract with the federal government

In indicating that reimbursements by the federal government for travel expenses of advisory committee members were not to be reported on a T1204 slip, CRA noted that the T1204 slip covers contract payments for government services, whereas here, the advisory committee did not have a contractual relationship with the government.

15 November 2005 External T.I. 2005-0154801E5 F - Service Contract Payments - Filing of T1204

T4A required where no T1204 filing required

The person making the “contractual payments” at issue was not a “federal body” as defined in Reg. 237(1), so that no form T1204 filing was required. However, Reg. 200(1) required the filing of a T4A.