Principal Issues:
1. What is the meaning of the term "new work location" for purposes of the moving expense deduction?
2. Can eligible moving expenses be deducted against the income of more than one employment at a "new work location" for purposes of subparagraph 62(1)(c)(i) of the Act?
Position:
1. Question of fact - depends on the context in which it is being applied.
2. Question of fact, but possibly yes.
Reasons:
1. Where a measure is required, the term must be restrictive, for example, in the case of a taxpayer moving from one neighbourhood to another. In this case, "new work location" would refer to the specific place of employment. In other circumstances, it may have a wide connotation, such as where a taxpayer relocates from one city to another. In this case, the "new work location" may refer to the city, in general.
2. Where a measure is not required, a taxpayer who relocates from one city to another may be entitled to deduct his or her eligible relocation expenses against employment income earned from more than one place of employment in the city (i.e., the "new work location").
2009 - 030846
XXXXXXXXXX Renee Sigouin
(613) 957-2128
August 5, 2009
