12 February 2007 External T.I. 2006-0205981E5 F - DAS programme de soutien financier pour handicapés -- summary under Paragraph (h)

A not-for-profit organization ("NPO") receives funds from the federal Opportunities Fund for Persons with Disabilities program of Human Resources and Skills Development Canada in order to provide funding to individuals with disabilities to assist them to enter or re-enter the labour market. CRA confirmed that the services provided by the NPO came within ITA s. 56(1)(r), so that they were “remuneration” under para. (h) of the definition thereof in Reg. 100(1) so that the payments were subject to source deductions and subject to an obligation to issue a T4A under Reg. 200(2)(c).