Given the great distance between the residence of new employees hired by the employer for a 24-month period and the employer's offices, they work from home. Although their contract of employment designates one of the employer's offices as their place of work, they are only required to attend there for a single three-day visit for training and team building activities.
The employer reimburses them in this regard for reasonable accommodation and transportation costs (train, bus, etc.) – or pays an allowance based on a kilometric rate for use of their private vehicles, as well as a meal allowance upon presentation of receipts.
Before concluding that the reimbursements were not includible pursuant to s. 6(1)(a), CRA stated:
[T]ravel between an employee's residence and a place of work other than a regular place of work is generally considered to be in the performance of the duties of the office or employment. …
Generally speaking, a regular place of work is any place to or from which an employee regularly reports or performs the duties of the employee’s employment. …
[Here] the place of work designated in the employment contract is not a regular place of work for the new employees. Consequently, travel between the residence of one of these employees and the employee’s place of work designated in the employment contract would be travel in the performance of the duties of the employee’s office or employment. In this case, amounts paid for travel expenses such as reimbursement for board, lodging and transportation will not have to be included in computing income from an office or employment pursuant to paragraph 6(1)(a).