Regarding the purchase by the Church of a residence for its retired pastors and missionaries, CRA stated:
Under [the function] test, the person must perform one of the following functions to be eligible for the deduction under paragraph 8(1)(c):
- is in charge of or ministering to a diocese, parish or congregation;
- is engaged exclusively in full-time administrative service by appointment of a religious order or religious denomination
…[T]he provision of housing to retired pastors and/or missionaries who no longer earn income from church office or employment will generally not result in a taxable benefit to be included in computing their income. Therefore, since these pastors and missionaries will not meet the function test described above, the CRA is of the view that they will not be eligible for the paragraph 8(1)(c) deduction.