The Employer hired new employees who were assigned to a special work site within the meaning of s. 6(6)(a)(i) or at a location described in s. 6(6)(a)(ii), and were required to provide their own accommodation and meals but, in some case, were entitled to receive a transportation allowance from a third party (not the Employer) respecting their return on weekends to their principal place of residence. If these transportation allowances are taxable under s. 6(l)(b), are they excluded under s. 6(6)(b)?
After noting the general taxability of allowances, CR went on to state,
Paragraph 6(6)(b) does not require that it be the employer who pays to the taxpayer the amount representing the value of the expenses incurred by the taxpayer for the transportation but requires that the amount of the board and lodging referred to in 6(6)(a) be paid by the employee’s employer. ...
Under the facts submitted ... the transportation allowances do not come within paragraph 6(6)(b), particularly because the employees do not receive an amount from their employer referred to in paragraph 6(6)(a).