24(1) 920532
A. Humenuk
(613) 957-2134
Attention: 19(1)
March 25, 1992
Dear Sirs:
Re: Staff Social Fund
We are replying to your letter of February 16, 1992 wherein you ask whether contributions to the staff social fund are deductible by the teachers who contribute to the fund.
The staff social fund uses the funds collected to purchase flowers or gifts for colleagues who are ill, graduate, retire or have births or deaths in their families.
In order for a donation or contribution for benevolent purposes to qualify for a deduction or a charitable deduction tax credit, the donee must be a registered charity, a charitable organization outside Canada to which Her Majesty in right of Canada has made a donation, a registered Canadian amateur athletic association, a qualifying housing corporation, a Canadian municipality, an agency of the United Nations, a qualifying university, or Her Majesty in right of Canada or a province. The attached pamphlet "Special or Limited Purpose Funds" explains the circumstances under which a fund such as yours might qualify for registered status.
In our view however, the objectives of the fund represent personal or social obligations of the employees towards each other and as such, the amounts contributed to the fund would likely be considered private benevolence and the fund itself would not likely qualify for registration as a charity.
We trust our comments will be of assistance to you.
Yours truly,
J.A. Szeszyckifor DirectorBusiness and General DivisionRulings DirectorateLegislative and IntergovernmentalAffairs Branch