Regulation 8900

Subsection 8900(1)

Paragraph 8900(1)(b)

See Also

Lapierre v. The Queen, 2019 TCC 18

UN-authorized agency was not a UN agency

The taxpayer, who was an employee of the International Security Assistance Force (ISAF) in Afghanistan serving as an international civilian consultant (ICC), was unsuccessful in establishing that his salary was exempted by s. 110(1)(f)(iii) on the basis that he was an employee of a prescribed international organization. This turned on establishing (under Reg. 8900(1)(b)) that the ISAF was a “specialized agency brought into relationship with the United Nations in accordance with Article 63 of the Charter of the United Nations.

In rejecting this claim, Lamarre ACJ stated (at para 21):

ISAF is not listed as a specialized agency of the United Nations. While the UN authorized ISAF, ISAF is a different entity from the UN.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(a) agency was not a NATO subsidiary non-military body 152
Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(f) - Subparagraph 110(1)(f)(iii) a Canadian resident working for a UN-authorized agency in Afghanistan was not exempted 110

Administrative Policy

9 April 2013 External T.I. 2012-0461051E5 F - Employee of an international organization

organization was not a specialized agency related to the UN

A Canadian citizen and resident is working with an organization that provides services with an unidentified relationship with the mandate of the United Nations. Under the terms of an international agreement, the individual’s salary is subject to domestic taxation including source deduction in the country where the individual is working.

In finding that the individual’s income could not be excluded from income through a deduction under s. 110(1)(f)(iii), CRA stated:

Considering the list of UN specialized agencies available on its website, we understand that XXXXXXXXXX is not a specialized agency related to the UN, in accordance with Article 63 of the [United Nations] Charter.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(a) exemption for UN officials did not apply to a Canadian resident 289
Tax Topics - Income Tax Act - Section 126 - Subsection 126(3) credit for local taxes imposed on salary of Canadian resident working for an international organization 241

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