| 923105 | |
| J.A. Szeszycki | |
| (957-2135) |
October 21, 1992
MR. READ'S OFFICEAUTHORSUBJECT OR CORPORATE CASE FILE
October 21, 1992
MEMORANDUM FOR MR. DENIS LEFEBVRE
SUBJECT: TUITION FEE REIMBURSEMENT
The purpose of this memorandum is to confirm the tax treatment of tuition fee reimbursements to employees, a matter that was raised at the recent Ontario Region meeting. The subject matter is referred to in a number of publications including the Employer's Guide to Payroll Deductions, interpretation bulletins IT-470R and IT-357R2 as well as the Revenue Canada pamphlet "Do Students Pay Income Tax?".
Each of these publications reflects the Department's position that the employer's reimbursement of all or part of tuition costs incurred by the employee related to courses taken primarily for the employee's benefit are properly treated as a benefit taxable in the hands of the employee. Courses taken at the request of the employer, primarily for the employer's benefit, and paid for by the employer would not result in a taxable benefit to the employee. However, where a course is taken on the employee's own time the presumption is made that the course is taken primarily for the employee's own benefit.
R.J.L. ReadDirectorGeneralRulings DirectorateLegislative and Intergovernmental Affairs Branch