The correspondent owns a home ("Property A") that is more than 300 kilometers from the work site that remained at the individual’s disposal throughout the reference period and has not been rented to another person. The individual also owns a property ("Property B") in the city where the site is located or at a distance that allows for commuting daily between that residence and the site. Is the allowance received while working at the work site excluded under s. 6(6)? CRA responded:
[A]lthough we find it unusual for a worker to solve a temporary housing problem by buying rather than renting, we have assumed that the work you performed at the special work site was work of a temporary nature.
The question of whether you have a self-contained domestic establishment elsewhere that is a principal place of residence … can be answered by examining the following factors, which are not exhaustive:
- What was your family's place of residence while you were working on the special work site?
- At what time did you acquire the self-contained domestic establishment near the special work site?
- Where would you have stayed if you were not employed at the special work site?
- What will happen to the self-contained domestic establishment near the special work site when your employment at the special work site ends?
… Thus, the allowance you receive for board and lodging may be excluded from computing your income only if your work at the special work site is of a temporary nature, if your Property A is a self-contained domestic establishment considered as your principal place of residence and if all other conditions for the application of subparagraph 6(6)(a)(i) are satisfied.