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.
CRA indicated that given that the employer’s office was not the employees’ regular place of employment, their travel between home and that office quailed as travel in the course of their employment. This signified that reimbursement for their travel expenses (e.g., for bus and hotels) was not a taxable benefit under s. 6(1)(a). Furthermore, for those who travelled using their own vehicles, a reasonable per-kilometre allowance payable by their employer would not be included in their income pursuant to s. 6(1)(b) by virtue of the exception in s. 6(1)(b)(vii.1), again because such travel would be considered to be in the course of their employment.
However, in finding that the other travel allowances would not qualify under s. 6(1)(b)(vii), the Directorate stated:
A workplace will only be considered an establishment of the employer if the employer is the owner or tenant of the workplace.
… [T]he employees' travel is therefore not for the purpose of travelling away from the municipality and, where applicable, the metropolitan area where the employer's establishment was located.