Smith – the provision of a free monthly parking pass to an employee was a taxable benefit

A flight attendant would not have received a taxable benefit from the provision to him, pursuant to a collective agreement, of a free monthly parking pass at the Calgary airport if it had been demonstrated that his employer (Jazz) provided the pass primarily for its benefit. This was not demonstrated, given that employees were free to choose any available means to get to the airport – and, in the case of the taxpayer, who had no other available means of transport to the airport, he would have gotten there on time even if he had to pay for his pass.

Neal Armstrong. Summary of Smith v. The Queen, 2017 TCC 62 under s. 6(1)(a).