APPENDIX V
Canadian Tax Provisions Dealing with Amateur and Professional Sports1

• The Income Tax Act allows for a deduction for any reasonable expense incurred by a business for the purpose of earning income.
• This provision applies to all businesses, including professional sports organizations.
• Examples of deductions by businesses include advertising in arenas, or advertising in a game program to promote a product or service.
• Examples of deductions by a professional sports team include marketing of team merchandise, or the advertising and promotion of team logo to generate ticket and/or merchandise sales.
• Common specific examples of deductible expenses for businesses include advertising on ice or floor surface at arenas, advertising on the rink boards, advertising on the scoreboard, and advertising and promotion on game programs
• The expense must be incurred for the purpose of earning income.

SUBJECT: INCOME TAX ACT

DATE: May 13, 1991

REFERENCE: Section 6 (subsection 2(3), sections 8, 115 and 212 and paragraphs 18(1)(p) and 125(7)(d) and the definitions of "retirement compensation arrangement" and "salary deferral arrangement" in subsection 248(1))

Application

This bulletin cancels and replaces Interpretation Bulletin IT-168R2 dated November 28, 1984.

Summary

This bulletin deals with the taxation of Canadian resident athletes and players (and prospective athletes and players) employed by professional sports clubs, such as football, hockey and similar clubs that participate in leagues having regularly scheduled games. In this bulletin, these individuals are referred to as "players". The bulletin discusses the items to be included in the income for tax purposes of such players and the timing and manner of these inclusions, as well as the deductibility by these players of certain expenses. The taxation of non-resident players is briefly discussed. Finally, the bulletin explains the tax treatment applicable to players who receive employment income through a corporation rather than from the sports club directly.

Discussion and Interpretation

1. For tax purposes, a player's income from employment includes any of the following items received in respect of employment:

(a) salaries, including income from personal service contracts (see 7 below),

(b) bonuses - for good performance, for allstar rating, for signing contracts, etc.,

(c) fees - for promotional activities or other special services performed on behalf of the club,

(d) living and travelling allowances (see 2 below),

(e) honoraria,

(f) payment for time lost from other employment,

(g) commuting expenses,

(h) free use of automobiles,

(i) awards - including cash and the fair market value of bonds, automobiles and other merchandise

(j) payments made by a club on a player's behalf that would otherwise be a non-deductible expense to the player, such as agents' fees, legal fees, income taxes, fines, etc.,

(k) other benefits.

2. Players' living and travelling expenses that are borne by the club are treated as follows:

(a) Non-accountable allowances paid to players, including those paid in the training and tryout period, are income to the player unless they are exempt by virtue of:

(i) subparagraphs 6(1)(b)(vii) and (vii.1) (see the current versions of IT-522 and IT-272 on the subject of travelling expenses for employees), or

(ii) Subsection 6(6) (see also the current version of IT-91, Employment at Special Work Sites).

Where a non-accountable allowance is income to a player, the player may deduct reasonable expenses to the extent that the requirements of paragraph 8(1)(h) are met.

(b) Reimbursement of a player's properly vouchered travelling expenses incurred for away-from-home games, or any other bona fide club business away from the club's home base, is not considered to be income to the extent that the expenses are reasonable in the circumstances. Similar expenses paid directly by the club are also not considered to be income of the player. However, amounts paid by the club in respect of the player (or reimbursed to the player) for personal travelling, such as for personal vacations or for family members, are considered to be income from the player's employment.

(c) The value of dining and dormitory facilities that are available to all players during the training and tryout period are not regarded as income to the players provided that the amounts are reasonable in the circumstances. Where a player lives in the general location of the training and tryout camp, and for personal reasons commutes daily from home, any allowance paid to the player for travelling, meals, etc., will be considered to be for personal living expenses and will be included in the player's income; the employee will not be eligible to claim expenses pursuant to paragraph 8(1)(h) against this income.

Deferred Income

3. A contract of employment may state that part of the player's remuneration will be payable on a deferred basis, referring either to a part of regular salary, or to some special amount such as an annual bonus. Deferring (or advancing) payments such as salary or bonus can affect the player's level of income for tax purposes in a year. Because of the variety of arrangements that may be made, each case must be considered separately, with due regard to the terms of the employment contract and of any trust or other agreement entered into by either party pursuant to that contract, including an employee benefit plan. Plans or arrangements to defer the salary or wages of a professional athlete for services as such with a team that participates in a league having regularly scheduled games are exempted from the rules in the Act applicable to a "salary deferral arrangement", as defined in subsection 248(1). Such plans or arrangements will also be excluded from the provisions in the Act applicable to a "retirement compensation arrangement", as defined in subsection 248(1), provided, in the case of a Canadian team, that the custodian of the plan or arrangement is a trust company licensed to do business in Canada and carries on business through a fixed place of business in Canada. In such cases, the plan or arrangement is treated as an employee benefit plan (see the current version of IT-502).

4. Generally, however, the player should include deferred remuneration in income for the year in which the player actually or constructively receives it, rather than for the year in which it was earned but not received. Where the year of inclusion in income is after the player has ceased to be employed by a particular club, subsection 6(3) is applicable (see the current version of IT-196).

Non-Residents

5. Where a player or former player is a non-resident or ceases to be a resident of Canada and receives remuneration or deferred remuneration on account of services performed in Canada for a Canadian club, the player will be liable for tax on that income pursuant to subsection 2(3), as calculated under section 115, except where the payment is one of those specified in section 212 to which Part XIII is applicable (for example, a retiring allowance or deferred profit sharing plan payments). Non-residents are also liable, by virtue of paragraph 115(2)(c.1), for tax on payments received for agreeing to enter into a contract for services to be performed in Canada (i.e. signing bonuses), for undertaking not to enter into such a contract with another party or as remuneration for duties or services to be performed in Canada, if the amount so received is deductible by the payer in computing income for Canadian income tax purposes. Consideration must also be given to the various tax treaties Canada has with other countries.

Deductions from Income

6. Players employed by sports clubs are limited to the same deductions from employment income as are available to any other employee by virtue of section 8. For example, fines paid by players personally are not deductible. Legal fees incurred in the negotiation of player contracts are also not deductible since paragraph 8(1)(b) stipulates that to be deductible, the fees must be incurred in collecting salary or wages owed by an employer or former employer or, after 1989, paid to collect or establish a right to such amounts.

Personal Services Business

7. Rather than employing a player directly, a sports club or organization may retain the services of a corporation with which the player is in turn engaged under a personal service contract. Income from such personal service contracts may be reported by a corporation if the services are in fact provided through the corporation and documentary evidence supports that fact. Such income will be considered to be income from a personal services business carried on by the corporation if it meets the definition of "personal services business". If it does, such income is taxed at full corporate rates. (If it does not, it may qualify for the small business deduction, provided the corporation is a Canadian-controlled private corporation.) Paragraph 125(7)(d) defines the expressions "personal services business" and "incorporated employee". These definitions deal with situations where a corporation has been interposed in what would normally constitute an employee-employer relationship. As a general rule, a corporation will be treated as carrying on a personal services business where a player:

(a) is, or is related to, a "specified shareholder" of the corporation, as defined in subsection 248(1), or

(b) provides services to a person or partnership that, in the absence of the corporation, would reasonably be regarded as the services of an officer or employee of the person or partnership.

An exception is provided where the corporation employs, throughout the year, more than five full-time employees or where the services are provided to an "associated corporation". For a discussion of the terms "personal services business" and "specified shareholder", see the current version of IT-73. The meaning of "associated corporation" is discussed in the current version of IT-64.

8. Paragraph 18(1)(p) restricts the deduction of expenses of a personal services business of a corporation to:

(a) the remuneration and the cost of other benefits or allowances provided to an "incorporated employee",

(b) certain expenses of the corporation associated with selling property or negotiating contracts that are ordinarily deductible from employment income, and

(c) amounts paid for legal expenses incurred by the corporation in collecting amounts owing for services rendered.

Paragraph 18(1)(p) ensures that the use of a personal services corporation does not permit the deduction of an expense which would not have been deductible had the income been earned directly by the player.

Endorsements and Public Appearances

9. Notwithstanding the above, income from the player's personal endorsements and public appearances negotiated between the player and third parties is business income against which necessary and reasonable expenses may be claimed. The contract may be structured to allow the income to be earned either directly by the player as business income or by a corporation as active business income subject to the small business deduction. Expenses claimed against such income could include costs of negotiating these endorsements and public appearance contracts, office expenses, travel expenses and accounting fees. Such income earned by a corporation is not income from a personal services business

Non-Profit Organizations

IT-496 February 18, 1983

REFERENCE: Paragraph 149(1)(l) (also paragraphs 110(8)(b) and (c), and sections 149.1 and 168)

1. The purpose of this bulletin is to comment on some of the factors that are considered when determining whether a club, society or association is, in a particular taxation year, exempt from income tax pursuant to paragraph 149(1)(l), that is, qualified to be a tax-exempt non-profit organization. Although a particular organization is qualified to be tax exempt pursuant to paragraph 149(1)(l), it may, pursuant to subsection 149(5), be subject to tax on its property income and on certain taxable capital gains. For the Department's interpretation of subsection 149(5), see IT-83R, "Non-profit Organizations - Taxation of Income from Property". The Department considers the expression "club, society or association", used in paragraph 149(1)(l) (hereinafter referred to as an association) to be wide enough to include an incorporated company.

2. In general terms, the conditions set out in paragraph 149(1)(l) that an association must comply with to qualify for exemption are as follows:

(a) it must not, in the opinion of the Minister, be a charity;

(b) it must be organized exclusively for social welfare, civic improvement, pleasure, recreation or any other purpose except profit;

(c) it must in fact be operated exclusively for the same purpose in (b) for which it was organized or for any of the other purposes mentioned in (b); and

(d) no part of its income may be paid, payable or otherwise made available for the personal benefit of any proprietor, member or shareholder, except in connection with the promotion of amateur athletics in Canada as described in 13 below.

3. The fact that a proprietor, member or shareholder of an association is a tax-exempt non-profit organization or a registered charity, will not relieve the association of the necessity of complying with the above conditions. In addition, the conditions to be complied with are neither waived nor altered by the fact that most or all of the assets and facilities of the association are leased to a tax-exempt organization or a registered charity. Where the association maintains that certain of its activities are carried on in trust for, or as agents for, another association, and the evidence supports this position, these activities will affect the status of that other association.

4. If, during a period in a particular year, an association is, in the opinion of the Minister, a charity within the meaning assigned by subsection 149.1(1), then it cannot qualify in that period as a tax-exempt non-profit organization. The Department considers this to be so whether or not it was a registered charity as defined in paragraph 110(8)(c) and, if registered, whether or not its registration has been revoked pursuant to section 168. An organization that is a charity as defined in section 149.1 may be exempted from tax only if it complies with one of the provisions in section 149. To qualify for exemption under paragraph 149(1)(f), the charity must be a "registered charity" as defined in paragraph 110(8)(c). For further information concerning registration of a charity see Information Circular 80-10, "Registered Charities".

5. To be tax-exempt an association must be both organized and operated exclusively for social welfare, civic improvement, pleasure or recreation or for any other purpose except profit. An association may also be organized and operated exclusively for any combination of these purposes. To establish the purpose for which an association was organized, the Department will normally look to the instruments by which it was created. These instruments may include letters patent, articles of incorporation, memoranda of agreement, by-laws, articles and so on. In general terms, "social welfare" means that which provides assistance for disadvantaged groups or for the common good and general welfare of the people of the community. "Civic improvement" includes the enhancement in value or quality of community or civic life. An example would be an association that works for the advancement of a community by encouraging the establishment of new industries.Under the categories of social welfare and civic improvement care must be taken to ensure that the purposes of the association are not those of a charity. "Pleasure or recreation" means that which provides a state of gratification or a means of refreshment or diversion. Examples are social clubs, golf clubs, curling clubs, badminton clubs and so on that are organized and operated to provide recreational facilities for the enjoyment of members and their families. The final category of "any other purpose except profit" is interpreted as a catch all for other associations that are organized and operated for other than commercial or financial reasons.

6. "Any other purpose except profit" may be used to describe the aims of an association whose activities are directed toward the general improvement of conditions within one or more areas of business. An example of this would be where an association was organized to advance the educational standards within a particular industry or profession, to publicize, improve and promote its objectives in a general way and to encourage the exchange of relevant technical information. If the activities of such an organization were consistent with these aims, then it would qualify for exemption provided all other conditions of paragraph 149(1)(l) were complied with in the year. However, the association will probably not so qualify if it is primarily involved, for example, in an activity that is directly connected with the sales of members' goods or services and for such services a fee or commission computed in relation to sales promoted. Such an association is normally considered to be an extension of the members' sales organizations and will be considered to be carrying on a normal commercial operation. "If the fees and commissions charged are well beyond the needs of the association and these earnings are accumulated and invested as described in 8 below by the association, this would be another reason why the association would not qualify as a non-profit organization exempt from tax.

7. The Department is of the view that an association is not operated exclusively for non-profit purposes when its principal activity is the carrying on of a trade or business. Some characteristics of an activity that might be indicative that it is a trade or business are as follows:

(a) it is a trade or business in the ordinary meaning, that is, it is operated in a normal commercial manner;

(b) its goods or services are not restricted to members and their guests;

(c) it is operated on a profit basis rather than a cost-recovery basis; or

(d) it is operated in competition with taxable entities carrying on the same trade or business.

8. An association may earn income in excess of its expenditures provided the requirements of the Act are met. The excess may result from the activity for which it was organized or from some other activity. However, if a material part of the excess is accumulated each year and the balance of accumulated excess at any time is greater than the association's reasonable needs to carry on its non-profit activities (see 9 below), the Department will consider profit to be one of the purposes for which the association was operated. This will be particularly so where assets representing the accumulated excess are used for purposes unrelated to its objects such as the following:

(a) long-term investments to produce property income,

(b) enlarging or expanding facilities used for normal commercial operations, or

(c) loans to members, shareholders or non-exempt persons.

This may also be the case where the accumulated excess is invested in a term deposit or guaranteed investment certificate that is regularly renewed within a year and from year to year, whether or not the principal is adjusted from time to time.

9. The amount of accumulated excess considered reasonable in relation to the needs of an association to carry on its non-profit activities is dependent on such things as the amount and pattern of receipts from various sources such as membership fees, training course fees, exam fees and so on. It is conceivable that there would be situations where an accumulation equal to one year's reasonably anticipated expenditures on its non-profit activities may not be considered excessive while in another situation an accumulation equal to two months' reasonably anticipated expenditures would be considered more than adequate. For example, a year-end accumulation equal to the following year's anticipated expenditures would probably be considered reasonable where an association carries out its "annual fund drive" in the last month of its fiscal period in anticipation of its non-profit activities planned for the following year. However, where another association raises its funds on a regular basis throughout the year, it may be difficult to justify a year-end accumulation in excess of an amount equal to its expenditures for one or two months. It is noted that where the present balance of accumulated excess is excessive or an annual excess is regularly accumulated it may indicate that the association's aims are two-fold, to earn profits and to carry out its non-profit purposes. In such a case, the "operated exclusively" test in paragraph 149(1)(l) would not be met.

10. To qualify for exemption, an association must not only be organized exclusively for non-profit purposes but it must in fact be operated in accordance with these purposes in each year for which it seeks exemption under paragraph 149(1)(l). A determination of whether an association was operated exclusively for and in accordance with its non-profit purposes in a particular taxation year must be based on the facts of each case which can be obtained only by reviewing all of its activities for that year. Such a determination cannot be made in advance of or during a particular year but only after the end of the year. An association that qualifies for exemption in a particular year may cease to qualify in a subsequent year by failing to operate in accordance with one of the purposes specified in paragraph 149(1)(l), by revising its objectives so that it is no longer organized in accordance with that provision or by otherwise failing to meet the requirements of that paragraph. See also IT-409, "Winding-up of a Non-profit Organization", for the Department's interpretation, in paragraph 3, as to where an association's tax-exempt status is lost in this special situation.

11. To qualify for exemption pursuant to paragraph 149(1)(l), no part of the income of an association, whether current or accumulated, may be made available for the personal benefit of any proprietor, member or shareholder of an association (hereinafter referred to as a member). An association may fail to comply with this requirement in a variety of ways. Some of these are as follows:

(a) the association distributed income during the year, either directly or indirectly, to or for the personal benefit of any member;

(b) the association has the power at any time in the current or future years to declare and pay dividends out of income; or

(c) the association in the case of a winding-up, dissolution or amalgamation has the power to distribute income to a proprietor, member or shareholder.

The presence of any of the circumstances described in (a), (b) and (c) would be conclusive evidence that income was payable or available for the personal benefit of a member, subject to the comments in 12 and 13 below and in 4 of IT-409 which deals with the distribution of taxable capital gains to members. To avoid possible difficulties regarding (c), an association may in its enabling documents provide that upon a winding-up, amalgamation or dissolution all of its assets and accumulated income are to be transferred to an organization with similar objects that qualifies for exemption pursuant to paragraph 149(1)(f) or (l) of the Act.

12. It is the Department's view that certain types of payments made directly to members, or indirectly for their benefit, will not, in and by themselves, disqualify an association from being exempted from tax pursuant to paragraph 149(1)(l). This view applies to payments such as salaries, wages, fees or honorariums for services rendered to the association, provided the amounts paid are reasonable and in line with those paid in arm's length situations for similar services. It also applies to payments made to employees or members of the association to assist them in covering their expenses to attend various conventions and meetings as delegates on behalf of the association, provided attendance at such conventions and meetings is to further the aims and objectives of the association. In addition, the Department considers the campaign expenditures of a political party, but not the payments to a candidate other than reimbursement of reasonable expenses, which will often result in an indirect benefit for a candidate, are not the type of personal benefit contemplated by paragraph 149(1)(l) that would cause the party to be denied exemption under that paragraph.

13. Without disqualifying itself under paragraph 149(1)(l), an association may distribute income to or for the benefit of any member that was an association the main purpose and function of which was the promotion of amateur athletics in Canada. This provision will normally be of particular advantage to a registered Canadian amateur athletic association that receives amounts from contributors who claim a paragraph 110(1)(a) deduction for contributions made to it. To obtain registration, on application to the Minister of National Revenue pursuant to paragraph 110(8)(b), an association must be both resident and established in Canada as a non-profit tax-exempt organization according to paragraph 149(1)(l), and its main purpose and function must be the promotion of amateur athletics in Canada on a nationwide basis.

14. An association that is tax-exempt pursuant to paragraph 149(1)(l) is not required to file an annual income tax return unless, in any particular year, it is a corporation, its income as a deemed trust (per subsection 149(5)) exceeds $500, or the Minister has demanded a return be filed. Although an association may not be required to file an annual income tax return, it must still comply with the other requirements of the Income Tax Act. For example, where such things as salaries and wages are paid, the association must comply with the withholding and remittance requirements as well as the requirements concerning the preparation of T4 and other forms.

SPECIAL RELEASE

Non-profit Organizations

IT-496 June 16, 1989

Paragraph 149(1)(l) (also sections 149.1 and 168 and the definitions of "registered charity" and "registered Canadian amateur athletic association" in subsection 248(1)). This Special Release includes comments on amendments to the Act resulting from Tax Reform.

Application

The purpose of this Special Release is to revise Interpretation Bulletin IT-496 dated February 18, 1983, to make certain changes in paragraphs 4 and 13 as a result of Tax Reform and to clarify paragraph 14. The changes in paragraphs 4 and 13 reflect the amendments to the Act under which the tax relief in respect of donations made by individuals is changed, for 1988 and subsequent taxation years, from a deduction in computing taxable income to a tax credit determined by formula as well as certain related amendments. Revised paragraph 14 clarifies the circumstances under which a tax-exempt association is required to file an annual income tax return. Minor changes have also been made to paragraphs 1 and 4 to update references to other Interpretation Bulletins and Information Circulars.

Bulletin Revisions

1. In paragraph 1 the reference to IT-83R, "Non-profit Organizations - Taxation of Income from Property" is replaced by the reference "IT-83R2, `Non-profit Organizations - Taxation of Income from Property'".

2. To reflect amendments to the law resulting from Tax Reform paragraphs 4 and 13 are replaced by the following:

"4. If, during a period in a particular year, an association is, in the opinion of the Minister, a charity within the meaning assigned by subsection 149.1(1), then it cannot qualify in that period as a tax-exempt non-profit organization. The Department considers this to be so whether or not it was, before or during that period, a "registered charity" as defined in subsection 248(1) (formerly defined in paragraph 110(8)(c) for taxation years before 1988) and, if registered, whether or not its registration has been revoked at any point pursuant to section 168.

Although an organization that is a charity as defined in subsection 149.1(1) will not be exempted from tax by paragraph 149(1)(l), an exemption from tax will be available under paragraph 149(1)(f) if the charity is a registered charity. For further information concerning the registration of a charity, see the current version of Information Circular 80-10, "Registered Charities".

"13. Without disqualifying itself under paragraph 149(1)(l), an association may distribute income to or for the benefit of any member that is an association the main purpose and function of which is the promotion of amateur athletics in Canada. This provision will normally be of particular advantage to a registered Canadian amateur athletic association that receives gifts from:

(a) corporations that are thereby entitled to a deduction in computing taxable income under paragraph 110.1(1)(a), or

(b) individuals who, as a result, are entitled to a deduction in computing tax payable determined by the formula in subsection 118.1(3).

(For taxation years before 1988, individuals and corporations contributing to registered Canadian amateur athletic associations were entitled to a deduction under former paragraph 110(1)(a) in computing taxable income.)

To obtain registration, on application to the Minister of National Revenue as required by the definition of a registered Canadian amateur athletic association in subsection 248(1) (former paragraph 110(8)(b) for taxation years before 1988), an association must be both resident and created under a law in Canada, and must be a non-profit tax-exempt organization described in paragraph 149(1)(l), whose main purpose and function is the promotion of amateur athletics in Canada on a nationwide basis."

3. Paragraph 14 is replaced by the following:

"14. An association that is tax-exempt pursuant to paragraph 149(1)(l) is required to file an annual income tax return for each particular year in which

(a) it is a corporation, or

(b) its income as a deemed trust (per subsection 149(5)) exceeds $500, or for any particular year in respect of which the Minister has demanded that it file a return. In the circumstances where an association is not required to file an annual income tax return, it must still comply with the other requirements of the Act.

For example, where amounts such as salaries and wages are paid, the association must comply with the withholding and remittance requirements as well as the requirements concerning the preparation of T4 and other forms."

SUBJECT: CANADIAN AMATEUR ATHLETIC
ASSOCIATIONS RECEIPTS - ISSUING POLICY

POLICY PURPOSE:

This document sets out departmental policy with regard to the issuance and control of receipts by registered Canadian amateur athletic associations (RCAAAs).

POLICY

1. The payment by the donor must meet the common-law requirements of a gift, i.e., it must be a voluntary transfer of property without consideration.

2. In light of paragraph 168(1)(f) of the Income Tax Act, the gift must be made to the RCAAA, without any implied or express condition or understanding that it be transferred to a local club or other issued beneficiary2.

3. There can be an agreement whereby the local club raising the funds receives back a percentage of the funds raised as financing for the club's activities that are consistent with two RCAAA's over-all purpose, but because of s. (168)(f) of the Act (see note 9), the specific percentage returned to the local club must not form part of any solicitation for funds by the local club, or any agreement with a prospective donor.

4. A significant amount of the monies raised should be retained by the RCAAA for its own use, for contingencies or to re-distribute to other clubs. An administration fee basically covering the expenses of receiving the monies and issuing the receipts is not considered a significant amount and would tend to indicate that the RCAAA is merely acting as a conduit for a local club's own purposes.

5. The RCAAA should maintain significant accountability and control over the issuance of receipts and the amount of funds raised. It is unacceptable for an RCAAA to "lend" its registration number to a member club.

6. A local club that receives "percentage" funding should account to the RCAAA and must enable Revenue Canada to verify whether receipts are issued according to the Act and this policy3. In light of the widespread practice of soliciting contributions from parents whose children receive direct support from the clubs, an RCAAA should require as part of its granting policy, that accounting from local clubs include the names of all those athletes who receive subsidized training. If during the course of an investigation the Department uncovers any substantial abuse at the local level under paragraph (1) above, the RCAAA will be deemed to have failed meeting the requirements of paragraph 166(1)(s) and subsection 230(2) of the Act unless it demonstrated to the Department's satisfaction that it had proper mechanisms in place to reasonably ensure the proper issuance of receipts.

7. Receipt-issuing should, if required, be delegated to a subordinate body at the provincial level only. It should not be sub-delegated by a provincial level association to member-clubs without the RCAAA's consent. The RCAAA must maintain direction and control over the receipt-issuing policies.

2 S. 168(1) (f) of the Act states that the Minister may propose the revocation of a registered Canadian amateur athletic association where the association ". . . accepts a gift or donation the granting of which was expressly or impliedly conditional on the association making a gift or donation to another person, club, society or association".

3 Subsection 230(2) I.T.A.: "Every (. . .) registered Canadian amateur athletic association shall keep records and books of account at an address in Canada recorded with the Minister or designated by the Minister containing:a) Information in such form as will enable the Minister to determine whether there are any grounds for the revocation of its registration under this Act;b) A duplicate of each receipt containing prescribed information for a donation received by it; andc) Other information in such form as will enable the Minister to verify the donations to it for which a deduction or tax credit is available under this Act.