Principal Issues: An entity, which is the central body for XXXXXXXXXX Roman Catholic parishes employs more than XXXXXXXXXX priests to minister to the parishioners of the parishes. When the priests retire, they may (i) begin to reside at parish rectories where they are provided with housing, food and common utilities; (ii) may live at an alternate residence or (iii) reside in a retirement home where care can be provided. With respect to each priest, the entity pays $XXXXXXXXXX per month (the "Amounts") to the rectory ((i) above), directly to the priest ((ii) above), or to the retirement home ((iii) above). Are the Amounts taxable as pension benefits under paragraph 56(1)(a)(i) of the Act or are they non-taxable on the basis that they are living allowances.
Position: The amounts are taxable as pension benefits.
Reasons: They are considered to fall within the general definition of a pension. The position is also considered to be consistent with paragraph 3 of IT-247, paragraph 2 of IT-196R2 and the definition of "superannuation or pension benefit" in subsection 248(1) of the Act.