When asked to comment on the meaning of "duties ... were of a temporary nature," CRA stated:
As a general rule, duties will be considered to be of a temporary nature if it can reasonably be expected that they will not provide continuous employment beyond a period of two years.
The determination of the expected duration of employment must be made on the basis of the facts known at its commencement. The agreed period for which the employee was engaged under the contract of employment or other terms of employment is one of the factors to be considered. In addition, when considering the facts of a particular situation, we would generally take into account, inter alia, the length of the contract, whether an employee is aware of the possibility of reappointment at the beginning of the first term, and whether there is any indication that the employees intended to work there on a temporary basis, and the possibility that the employees' contract could be renewed. For example, if the term of the employment contract is generally two years and the possibility of renewal is known at the outset and/or if it is often the case that the employees are able to renew their contracts, we doubt that the employees' duties are of a temporary nature and, in our view, the reimbursement of expenses could not be excluded from the employees' income pursuant to subsection 6(6). However, if the employees were offered employment for a period of three years, with no possibility of extension, it is our view that a single three-year term could be work of a temporary nature.