ROUND TABLE - CGA - JANUARY 10, 1992
| Officer: M. Querry | |
| File: 5-913013 |
QUESTION #24
A non-profit association sets up various committees of members to provide services to its members. None of the committee members is an employee of the organization and none receives any remuneration for committee work. However, they are reimbursed for kilometres travelled to attend meetings at the association's headquarters.
What tax treatment should be given to these individuals' travel expense refunds?
Would your answer be the same if the meetings were held elsewhere than in the organization's headquarters, for example in a hotel conference room?
If the association is Canadian, the committee meeting is held in Calgary, the committee members come from the ten provinces and the travel expenses (airplane, hotel, meals) are reimbursed, what tax treatment should be given to these reimbursements?
ANSWER
The question whether an individual holds an office or employment is a question of fact. We are of the opinion that the fact that a member of a non-profit organization receives no remuneration for committee work is not ipso facto conclusive in making such a determination.
Moreover, the Department has established certain administrative policies with respect to travel expense allowances and reimbursements for travel expenses paid to employees, which can be found in Interpretation Bulletin IT-522. At paragraph 54 of this bulletin, it is indicated that usually a reimbursement or an accountable advance for travelling expenses is not income in the hands of the employee receiving it, unless it represents payment of the employee's personal expenses. For example, in a situation where a member must travel to a location situated outside the municipality and the greater urban area in which the organization's headquarters is located, pursuant to the duties of his office or employment with the organization, reasonable allowances paid to him and reasonable travel expenses for which he is reimbursed need not be included in the computation of the employee's income.
Our comments concerning expenses reimbursed and allowances paid with respect to travel expenses incurred by members of the board of directors and our comments concerning the rules with respect to maintaining non-profit organization status in the case of such payments also apply to payments made to committee members.