23 February 2005 External T.I. 2004-0093921E5 F - Déménagement d'un employé-Paiement de frais -- summary under Paragraph 6(1)(a)

The corporation hired someone to search for accommodation in Canada of its new president, who was moving to Canada to take up his position, and to take care of the administrative formalities of obtaining a health insurance card, a social insurance number, a driver's licence and opening a bank account. In finding that there was no taxable benefit arising from the related costs being borne by the corporation, CRA stated:

[T]he payment of the house-hunting fee will not represent a taxable benefit to the president of the corporation in the same way as the reimbursement or payment of house-hunting travel expenses. It is our view that the payment of these fees is part of the reasonable moving expenses paid for the employer to benefit from the services of the president at the Canadian location.

Similarly, it is necessary for the president to have a social insurance number in order to be employed in Canada. …

While there may be arguments that the costs of obtaining a health insurance card and opening a bank account are personal costs that do not benefit the employer, there are also arguments for considering these costs as part of the reasonable costs of the president's move to Canada. We could then also consider that the fees for the administrative formalities relating to these two items do not enter into computing the president's employment income.

Topics and taglines
Tagline
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
640589
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
640590
Extra import data
{
"field_editor_tags": [],
"field_roundtable_subquestion": "",
"field_stub": false,
"field_legacy_header": ""
}
Workflow properties
Workflow state