| 913098 | |
| R.B. Day | |
| (613) 957-2136 |
19(1)
January 15, 1992
Dear 19(1):
We are writing in reply to your letter of October 29, 1991, wherein you requested our views as to whether the expenses reimbursed to employees pursuant to the following two benefit programs offered by one of your clients would be considered to be taxable benefits to the recipients thereof pursuant to paragraph 6(1)(a) of the Income Tax Act (the Act).
Sick Dependant Care Plan. This plan reimburses additional expenses incurred to care for a sick or disabled dependant to enable the employee to report to work.
Overnight Dependant Care Plan. This plan reimburses additional expenses incurred to care for a dependant child or disabled dependant to enable the employee to work significantly later than normal business hours or to travel out of town on business.
Our comments
It is our opinion that the amounts reimbursed by the employer and received by the employees would be amounts received "in respect of, or by virtue of an office or employment," and as such would be taxable in the hands of the recipients pursuant to paragraph 6(1)(a) of the Act.
We trust our comments will be of assistance to you.
Yours truly,
J. Szeszyckifor DirectorBusiness and General DivisionRulings DirectorateLegislative and IntergovernmentalAffairs Branch