ARTIST GRANT – BUSINESS?

In a June 22, 2018 Technical Interpretation (2018-0759891M4, Wirag, Eric), CRA stated that, in determining whether a grant or other form of assistance received by an artist is from a business (an activity carried on with the intention to earn business income in a sufficiently commercial manner), they review factors such as: representation by a dealer or agent; qualifications through public education and public recognition; and revenue from sales, commissions, royalties, fees and grants. No one factor is more important than the other, and all relevant factors are considered together.

ability to deduct expenses exceeding revenues for a business

Editors’ comment
See VTN 443(4) where CRA confirmed that only the portion of a research grant which exceeds related expenses should be included in income (Paragraph 56(1)(o)). Where expenses exceed the grant, there is no deduction for excess expenses.

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