CRA declines to provide comfort that travel allowances of employees at accounting firms for travel on their audit engagements are non-taxable

Are employees of auditing firms taxable on the travel allowances they receive for travelling to and from their home and the audited premises in the context of audit engagements lasting about two weeks? CRA noted that in T4130 it had stated that its concept of a "regular place of employment” included, for example, “a client's premises when an employee reports there daily for a six month project” and “a client's premises if the employee has to attend biweekly meetings there,” and then indicated that it could only make a few general comments, including:

If the place of business of a client of the firm constitutes a "regular place of employment" for the auditor, the travel between the auditor’s residence and the place of business of that client is considered personal travel and is therefore not considered travel "in the performance of the duties of the employee’s office or employment". Consequently, the allowance received from the firm by the auditor in the year for this travel must be included in the auditor’s income by virtue of paragraph 6(1)(b).

This was not as bad as stating that the allowances were clearly taxable. It took the Directorate almost four years to respond to this question.

Neal Armstrong. Summary of 19 July 2018 External T.I. 2014-0551941E5 F under s. 6(1)(b).