Employees were provided with a minivan only during periods that they were on-call to respond to emergency calls. The minivans (bearing the employer’s name) were specially adapted so that they could be used to transport all the equipment required to carry out the employees’ employment-related tasks.
After discussing whether the minivans were automobiles, CRA stated:
[T]he use by an employee of a motor vehicle made available to the employee by the employer for travel between the employee’s residence and the employee’s usual place of work, as well as all travel not directly related to the employee’s employment, is considered personal use. This is the case even if the motor vehicle is made available to an employee in order that the employee can respond quickly to an emergency situation while on call. However, when an employee uses a motor vehicle from home to travel to an emergency location other than the employee's usual place of work, or returns from that location to the employee's residence, the use of the motor vehicle will generally be considered to relate to the employee's employment.