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After noting that “Carpooling appears to be replacing the passenger’s travel between home and work in their own employer assigned Vehicle,” so that “there is a connection between carpooling and the passenger’s employment and therefore, the passenger would be in receipt of a taxable benefit with respect to employer provided travel,” CRA stated: In a carpool scenario, a reduction in the value of the travel benefit may be warranted based on loss of privacy or quiet enjoyment, additional travel time, etc. … Employees and employers should keep records on employee travel in support of the particular position taken. ...

In discussing whether the s. 55(3)(a) exemption would be available for the dividends deemed to arise in 5 above in light of the s. 55(4) exclusion, and after noting that it had insufficient information to answer this question, CRA stated: In connection with a request for an advance ruling, we would require additional information such as, inter alia, the age of the parent and children, the involvement of the parent and children in the businesses prior to the reorganization and thereafter, the experience and training of the children to operate such businesses, the identity of the trustee or trustees of Trust A, the length of time that A has held voting shares of the capital stock of Newco and Corporation A, etc. ...