4 January 2022 External T.I. 2016-0644861E5 F - Travail de nature temporaire -- summary under Subparagraph 6(1)(a)(i)

After being asked how to apply the condition respecting "duties … of a temporary nature" in s. 6(6)(a)(i), in various contexts, including where an employee is assigned successively to two projects in the same region or city, or assigned successively to two separate projects at the same place of work, CRA referred to its positions on duties of a temporary nature in IT-91R4 and then stated:

For the purposes of subsection 6(6), we are of the view that the place where an employee performs work of a temporary nature (i.e., a special work site) is a particular place of work and not a general geographical area such as a city.

Consequently, it is generally from a special work site that all relevant facts of a project, or a particular phase of a project … must be examined in order to determine whether the work performed by an employee was of a temporary nature for the purposes of subparagraph 6(6)(a)(i).

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