Principal Issues: What are the prescribed international organizations referred to in subparagraph 110(1)(f)(iii) of the Act?
Position: The organizations referred to in Regulation 8900(1) of the Income Tax Regulations
Reasons: Law
Signed June 3, 2010
XXXXXXXXXX
Dear XXXXXXXXXX :
The office of the Honourable James M. Flaherty, Minister of Finance, forwarded to me a copy of your correspondence, which I received on March 31, 2010, regarding the international organizations referred to in subparagraph 110(1)(f)(iii) of the Income Tax Act.
You are asking for a list of the international organizations referred to in the above-noted provisions.
Subparagraph 110(1)(f)(iii) of the Act allows taxpayers to deduct, when calculating their taxable income for a tax year, any amount that is income from employment with a prescribed international organization to the extent that it is included in computing the taxpayer's income for the year. Regulation 8900(1) of the Income Tax Regulations states that the following international organizations are prescribed:
(a) the United Nations; and
(b) each international organization that is a specialized agency brought into relationship with the United Nations in accordance with Article 63 of the Charter of the United Nations.
The Charter of the United Nations sets out, amongst other things, who may enter into agreements with agencies for the purposes of being brought into a relationship with the United Nations. These agencies are referred to as specified agencies. You can find the full text of the Charter of the United Nations at www.un.org/en/documents/charter. The United Nations Web site sets out the specialized agencies at www.un.org/en/aboutun/ structure/index.shtml. The specialized agencies do include the World Bank Group, the International Monetary Fund, the United Nations Industrial Development Organization, and the International Fund for Agricultural Development.
The regional development banks referred to in your correspondence are not listed as specialized agencies. However, there are instances when, by the terms of the constating documents of an organization, the member countries who establish the organization agree not to tax the salaries or emoluments of directors, alternate directors, officers, and employees. You can contact organizations not listed as specialized agencies by the United Nations directly to make such enquiries.
I trust that the information I have provided is helpful.
Yours sincerely,
Keith Ashfield
Minister of National Revenue
Katharine Skulski
613-957-8976
2010-036263