XXXX
C. Tremblay (613) 957-2139
March 17, 1987
XXXX
This is in reply to your letter of December 19, 1986, wherein you requested a ruling with regard to a travel allowance, which you receive from your employer.
XXXX
We do not agree with your view. To qualify for exclusion from income, the allowance should be received in connection with the performance of the duties of employment, and should be computed by reference to time actually spent in travelling on your employer's business. The expenses incurred by an individual for travelling between home and an employer's place of business at which the individual ordinarily reports for work are considered personal or living expenses. Accordingly, any allowance received from an employer to cover such expenses are included in the individual's employment income for tax purposes.
We wish to indicate that these comments constitute an opinion and not an advance income tax ruling. Advance rulings are given in respect of proposed transactions which are not of a continuing nature. The procedures and costs involved for requesting an advance income tax ruling are set out in Information Circular 70-6R, and Special Release, copies of which are enclosed.
We trust that our comments will be of assistance.
Yours truly,
for Director Small Business and General Division Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch
Enclosures