| 19(1) | File No. 5-9616 |
| J.D. Jones | |
| (613) 957-2104 |
March 28, 1990
Dear Sirs:
Re: Recruitment Payments to Donors
This is in reply to your letter of February 5, 1990, addressed to the Winnipeg District Taxation Office regarding the above-noted subject which has been referred to this office for reply.
It is our understanding 24(1)
Based upon the above, you have asked that we confirm that payments to donors for samples are non-taxable income to the donor.
We advise that, in our view, the payments to the donors in the above situation is taxable income in the hands of the recipients as income from a source pursuant to section 3 of the Income tax Act. Accordingly, the payments should be reported on T4A supplementaries.
We trust our comments are of assistance to you.
Yours truly,
for DirectorBusiness and General DivisionSpecialty Rulings DirectorateLegislative and Intergovernmental Affairs Branch