A not-for-profit organization described in s. 149(1)(l) (the “Organization”) operates in two different regions and maintains two establishments, one in each of these regions. Board meetings generally occur every two months, in an evening, and alternate between the two locations. They work full-time in other employment or carry on a business. In addition to their attendance fees (which are taxable under s. 6(1)(c)), the Organization pays a travel allowance to those who must travel between regions to attend meetings. CRA stated:
[S]ubsection 81(3.1) could apply to the travel allowance paid by the Organization to its directors who have to travel from one region to another to attend meetings of the Organization's board of directors if all the conditions of that subsection were otherwise satisfied.