volunteer

Before going on to infer a broader meaning of “volunteer” in the context of s.

Before addressing the volunteer firefighter tax credit, CRA addressed whether amounts received by a part-time firefighter with modest remuneration might be exempt on general principles, stating:

In finding that firefighters in a particular town were not entitled to the credit, CRA stated:

If the amounts paid represent only a small amount for the services rendered compared to what it would have cost under the same circumstances to have the same work performed by a regular full-time or part-time employee, we will generally consider the firefighter to be acting as a volunteer.

A registered charity sends volunteers on missions to developing countries and pays them an allowance of $X per day. After finding that "remuneration that is quite unrepresentative of the services rendered would not be taxable," CRA turned to a question as to whether the charity could issue donation receipts in accordance with CPC-012 if the volunteers declined the allowance, and stated (TaxInterpretations translation):