Words and Phrases - "principally performs"
18 June 2007 Internal T.I. 2007-0231861I7 F - Principale place d'affaires
Regarding the application of s. 8(13)(a)(i) to home office expenses incurred by Quebec real estate agents under a contract of service, the Directorate stated:
In order to determine whether a real estate agent's home office meets the requirement set out in subparagraph 8(13)(a)(i), it is necessary to refer to the amount of time that the agent physically spends in the premises of the agent’s home set aside for the purpose of his or her work. Thus, if more than 50% of the time spent on all of the agent’s employment-related duties is attributable to time spent in those premises, subject to paragraph 8(13)(b), an amount may be deducted. … [T]ime spent on the road, on the premises of properties for sale, and at the real estate broker's place of business cannot be assimilated to time spent working at the home office.