In order to give young graduates work experience abroad in a field related to their studies, they were placed overseas in a six month placement and received an allowance of $1,300 per month consisting of $500 paid for accommodation, $200 for travel and $600 for food.
The Directorate reviewed the conditions for the application of the exemption under s. 6(6) and noted, for instance, that the length of the placement would clearly qualify as temporary but that the exception would not be available if the Canadian home base of the interns was their parents’ home. If all the conditions were satisfied, the full amount of the allowances could be covered by the s. 6(6) exemption.