CRA notes that the travel allowance exemption in s. 6(6)(b)(i) does not include travel from a “temporary” place of residence

As noted in a previous post, CRA gave a “question of fact” response to a query as to whether employees of auditing firms are taxable on the travel allowances received for travel to and from their home and the audited premises in the context of audit engagements lasting about two weeks. This turned on whether the client premises were “regular places of employment.” In commenting further on the RPE concept, CRA stated that:

[A] work location may be considered to be a RPE for an employee even though the employee may only report to work at that particular location on a periodic basis (e.g., once or twice a month) during the year.

Turning to the exemption in s. 6(6)(b)(i) for an allowance for transportation between the taxpayer’s “principal place of residence” and a (temporary) special work site, CRA stated:

[I]f a special work site is a RPE for an employee, the value of a reasonable employer-provided allowance or reimbursement for travel between the employee’s temporary place of residence (e.g., a hotel, camp, rental home, etc.) and the special work site is included in the employee’s income under paragraph 6(1)(a) or (b).

Neal Armstrong. Summaries of 4 December 2018 External T.I. 2016-0670851E5 under s. 6(1)(b) and s. 6(6)(b)(i).