Talbot – Tax Court of Canada finds that a taxpayer did not “reside” in a northern region where he stayed there only during work days in a room provided by his employer

S. 110.7 allows individuals who satisfy conditions, including that they have resided for a period of at least six consecutive months in a "prescribed zone," to take a special deduction in computing their taxable income for the year for travel and accommodation expenses.

The taxpayer would work in a remote area of Quebec for a 22 work-day stint while staying in a room provided by his employer, and then vacate the room and return with his personal belongings to his home in Quebec City for 20 days off, before repeating the cycle. Fournier J found that this was insufficient to consider that the taxpayer ever “resided” in the prescribed northern zone, stating that “The most that can be said is that he intermittently stayed at the work site.”

Neal Armstrong. Summary of Talbot v. The Queen, 2018 TCC 94 under s. 110.7(1).