A member of the Canadian armed forces was assigned to the U.S. and occupied an apartment there for several years and did not maintain a residence in Canada. While in the U.S., and, while there, received a (i) rent allowance which paid him for the excess of his actual rent expense minus a deduction for the notional cost of accommodation in Canada, but without this deduction having been indexed over the years for inflation, (ii) a similar utilities allowance, and (iii) a Foreign Service Premium to compensate for other financial detriments of a foreign posting.
The Directorate first quoted a statement in 2005-0158871E5 that:
[A] "representation allowance" in the context of subparagraph 6(1)(b)(iii) … is an allowance paid to a worker having to work outside the country and is intended to lessen the inconveniences arising out of having to move abroad, being subject to different living conditions and, where applicable, having to face a higher cost of living.
The Directorate then concluded that the foreign service premium so qualified.