Private ruling: Crowd funding grant
Date of advice: 13 September 2019
Published: November 2019
Ruling period: Year ending 30 June 2019

Ruling: Q1: Is the grant received assessable under section 6-5 of the Income Tax Assessment Act 1997 (ITAA1997)? | A1: No. The crowdfunding grant was to assist your residency overseas. It had no connection with your income earning activities, or a business carried on. Therefore, the grant is not considered to constitute assessable income pursuant to section 6-5 of the ITAA 1997.

Relevant facts and circumstances: The fundraising platform especially formulated for professionals. You did not work for the company and set up the crowd funding through the fund for your residency overseas. You asked your connected entities to yourself for donations, for the crowd funding and this was paid direct to the fund. You received a grant from the fund this totalled $XXXX, this amount is after the fund took out their administration fee. You contributed your own personal savings towards the residency and trip overseas. During your residency overseas, you resided at the Foundation, which is a not for profit organisation, they provided you with a studio and exhibition space. The residency at the foundation provides skill development and networking opportunities to its resident professionals and facilitates group expedition and open studio weekend.

Relevant legislative provisions: Income Tax Assessment Act 1997 section 6-5