26 March 2015 Internal T.I. 2013-0503031I7 F - Existence d’une source de revenu -- summary under Income-Producing Purpose

After finding that the taxpayer’s expenses were likely non-deductible as his activities likely were a hobby rather than a business, CRA went on to comment on the deductibility of his travel expenses in the event that (contrary to this conclusion) it was determined that he was carrying on a business, stating:

[T]he use of a car for personal purposes generally includes travelling between the individual's home and place of business unless it is established that the home is the principal place of business.

...According to case law, the principal place of business of a taxpayer represents where the activities necessary for the carrying on of the business take place, including calling customers and suppliers, issuing invoices, maintaining payroll and other books and records, communicating with the authorities to obtain permits, preparing tax returns, collecting receivables, handling complaints, developing business plans, preparing the financial statements and engaging with accountants and lawyers.

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