Words and Phrases - "scholarship"

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23 March 2011 External T.I. 2010-0382351E5 F - Bourses d'études ou subventions de recherche

research was conducted in course of doctoral studies, so that expenses thereof non-deductible

Can an individual who received various scholarships in the course of pursuing a doctorate at a university, deduct the costs of acquiring a motor-powered glider in conducting a research project? In responding “no,” CRA stated:

Where a taxpayer continues the taxpayer’s studies and receives scholarships or fellowships, the taxpayer will not be able to deduct the expenses incurred for the studies for which the scholarships were paid to the taxpayer … [whereas] paragraph 56(1)(o) permits a taxpayer to deduct expenses incurred in a taxation year for the purpose of continuing the taxpayer’s research.

… If the principal purpose of the award is pursuing the recipient's education and training for the recipient (for example, if the recipient is studying for a PhD), the scholarship is included in accordance with subparagraph 56(1)(n)(i), even though research is being done to achieve that objective.

On the other hand, if the principal purpose of an award is to perform research for its own sake (for example, to deepen knowledge in a particular field by making a discovery or finding a new interpretation of known facts), the award is considered to be a research grant and is included pursuant to paragraph 56(1)(o). Where such research allows the recipient to continue the recipient’s education and training, such a benefit does not negate the principal purpose of the grant provided that such benefit could be considered to be a secondary purpose of the grant or an inevitable but incidental benefit.

… In your situation, the scholarships you receive seem to be scholarships or fellowships, not research grants, because …the research you are currently conducting is focused on obtaining a postgraduate degree.

Words and Phrases
scholarship