6 September 2011 Internal T.I. 2011-0401191I7 F - Automobiles mises à la disposition des employés -- summary under Subsection 6(2)

Executives were each provided with an automobile that was not suitable for winter use, so that for 5 months of the year it was kept in a storage yard with the executive not being given rights of access. The Directorate stated:

to the extent that it can be demonstrated that employees have no rights, under any circumstances, to use Automobiles during the months of November, December, January, February and March, we are led to believe that executive employees do not have access to or control over Automobiles when they are in storage. That prohibition on use should generally be evidenced in writing … . In such a case, the benefit for reasonable standby charges should be calculated on the basis that the Automobiles are made available to the executive employees for a period of 7 months per year.

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