Words and Phrases - "enable"

The taxpayer lived in Toronto. He worked in Burlington beginning in 2004, was promoted to management in 2007, and moved to Oakville in 2008, 50 kilometers closer to his workplace than his Toronto home. Webb J found that the taxpayer's moving expenses were deductible as an eligible relocation, notwithstanding that the relocation occurred approximately four years after his employment commenced.

The term "new work location" originated when the Act required that the taxpayer cease to be employed at an old work location in order to deduct relocation expenses. Because that requirement was repealed, it is no longer reasonable to construe the phrase "new work location" as imposing a timeliness requirement in the definition of "eligible relocation" (paras. 10-11). Webb J stated (at para. 8):

It should also be noted that the same label "new work location" was also placed on the educational institution if the taxpayer was a student. This emphasizes the point that "new work location" is simply the name or the label that was placed on the particular location. The words used as part of this label (in particular new and work) should not be used to define the expression "new work location".

The taxpayer's relocation occurred "to enable" him to be employed at his workplace, because his promotion came with added responsibilities that made his previous commute unmanageable.