| 24(1) | 900397 |
| Rick Mundell | |
| (613) 957-2139 | |
| Attention: 19(1) | EACC9336 |
August 9, 1990
Dear Sirs:
Re: Application of Paragraph 67.1(2)(e)
This will reply to your letter of April 10, 1990 concerning a request for a technical interpretation of paragraph 67.1(2)(e) with respect to board and lodging allowances given to employees at special work sites. We apologize for the delay in our response.
In the hypothetical situation presented a corporate contractor carries out a substantial portion of its activities at locations which meet the definition of a "special work site" as defined in subparagraph 6(6)(a)(i). Under its union contract it pays its employees at special work sites a daily board and lodging allowance, which is treated as a tax free allowance pursuant to subsection 6(6) by the employees. Your concern is whether the portion of the allowances relating to board is eligible for the exception provided by paragraph 67.1(1) to determine the amount of food and beverages that is subject to the 80% limitation.
Draft amendments were issued by the Department of Finance on July 13, 1990 which may clarify this area. As further review of this matter appears to be necessary we are unable at this time to provide the technical interpretation of paragraph 67.1(2)(e) which you have requested.
Yours truly,
for DirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch