allowance

14 February 2002 Internal T.I. 2001-0107757 F - PENSION ALIMENTAIRE POUR ENFANTS -- summary under Support Amount

Amounts required to be paid to Madame under a separation agreement were not support amounts. The amount was a support amount because the recipient could use it as the recipient saw fit. In particular, although the agreement referred to expenses that the amounts could be applied to, she was not required to so apply such amounts and, therefore, she had reasonable discretion as to the amounts’ use.

15 November 2016 Internal T.I. 2015-0577201I7 F - Employés du transport -- summary under Subparagraph 6(1)(b)(vii)

A trucking company pays its employed long-haul drivers allowances for accommodation expenses of $0.04 per kilometer (scenarios 1 and 3) or of $75 per day spent away (scenario 2). (In scenario 3, they also receive wages of $0.36 per kilometre.) The employees each sleep in the truck’s cab as a security measure, so that no expenses are generally incurred by them for accommodation – but their meal expenses, amounting to around $40 per day, are approximately twice the allowance amounts in scenarios 1 and 3 based inter alia on assumptions as to the number of kilometres travelled.

7 April 2015 External T.I. 2014-0552731E5 F - Apportez vos appareils personnels / BYOD -- summary under Paragraph 6(1)(b)

Employees, who are required to use cell phones in the performance of their duties and to have their cell phone contracts approved by the employer, but bear the monthly costs of the contracts personally. However, the employer pays each a fixed amount based on the particular requirements of each employee not in excess of their costs. The employees do not systematically provide copies of their invoices, but are required to retain them for possible future inspection. CRA stated (TaxInterpretations translation):

By services, 28 November, 2015

The Queen v. Côté, 99 DTC 5788, 1999 CanLII 8469 (FC) (FCTD) -- summary under Paragraph 6(1)(b)

The taxpayer, who was a senior Quebec civil servant, was taxable on a lump sum equal to four weeks' salary that compensated him for expenses of a compulsory move from Quebec City to Montreal given that the amount qualified as an allowance (i.e., a limited and predetermined amount that was paid to cover personal expenses in lieu of reimbursement and for which there was no obligation to account).

By services, 28 November, 2015

ExxonMobil Canada Ltd. v. Canada, 2010 FCA 1 -- summary under Subparagraph 174(a)(iv)

The appellants were required to relocate their employees to different locations as part of their business. In addition to reimbursing direct moving costs, their relocation policy entailed paying the relocated employees a moving allowance in respect of incidental expenses (e.g., draperies, blinds and carpeting for the new premises, costs of cancelling and entering into new service contracts and the replacement of items which could not be shipped.) The appellants claimed ITCs in respect of the moving allowances on the basis of s. 174.

allowance