12 November 2004 External T.I. 2004-0080051E5 F - Allocation et remboursement de dépenses-employé -- summary under Paragraph 6(1)(b)

Employees are compensated between $1.00 and $2.00 per hour for the employment-related use of their own tools, equipment, and supplies (e.g., fax machine and supplies, computer, or video cameras), or $0.30 per minute of their cell phone usage, and are also compensated for their internet use. In indicating the inclusion of these amounts under s. 6(1)(b), CRA stated:

[A]n amount calculated on the basis of an estimate of possible costs is an allowance, not a reimbursement. The same is true of an amount paid on the basis of a rate per hour of use. If, on the other hand, the employer makes a payment to the employee based on receipts or vouchers submitted by the employee, this would be a reimbursement.

In this situation, we are of the view that the $1.00 to $2.00 per hour for use of equipment and supplies is an allowance. If the amount of $0.30 per minute for cell phone use is calculated based on an estimate of costs rather than actual costs, this amount would also constitute an allowance.

… [W]e do not know whether the compensation paid for the Internet fees represents an allowance or a reimbursement of actual expenses incurred. … If it is … a reimbursement of actual expenses … [and] the facts show that this Internet access is essential for the employees to perform their employment duties, we are of the view that it is unlikely that a significant taxable benefit will result to the employees from the reimbursement of the Internet and modem fees. In such a case, the reimbursement would not be included in employment income. …

[S]upplies [under s. 8(1)(i)](iii)] would not include the cost of tools or equipment or amounts paid for a cell phone connection or communication licence fee.

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