Principal Issues: Application of subsections 6(19) to 6(22) of the Income Tax Act sections to payments received during the period of February 23, 1998 to December 31, 2000.
Position: An employer-paid housing loss is fully taxable unless it is paid for an eligible relocation, generally in which case, the first $15,000 is not taxable and one-half of the excess amount is taxable. A payment made before February 23, 1998, is not taxable under the new rules, as well as any payment made on or before December 31, 2000, for an eligible relocation if employment at the new work location began before October 1998.
Reasons: Provisions are applicable to the 2001 and subsequent taxation years in respect of an eligible relocation of an individual in connection with which the individual begins employment at a new work location before October 1998; and in any other case, after February 23, 1998.