CRA confirmed that a modified version of a 1998 agreement between the Commission de la Construction du Québec (the "CCQ") and CRA was in effect. Where construction employees received a daily allowance to cover the costs of meals and accommodation while away from home and at a construction site, it was agreed that the following portions thereof would be considered to be for meal expenses that were subject to the s. 67.1(1) limitation (to the extent that the s. 67.1(2) exceptions did not apply):
|
Amount of daily allowance |
Meal portion |
|
$75 and under |
15% of the balance |
|
Between $75 and $100 |
$11.25 plus 20% of the balance |
|
Between $100 and $125 |
$16.25 plus 30% of the balance |
|
Over $125 |
$23.75 plus 40% of the balance |
CRA went on to state:
[T]he agreement with the CCA can be applied to all taxpayers in circumstances similar to those described in the agreement, regardless of the industry in which they are engaged.