Does a change in the circumstances of a taxpayer’s employment have changed to a “new work location” under the definition of eligible relocation?

The Appellant cites the principles enunciated in Wunderlich v. The Queen[2] as authority for the proposition that a change in the circumstances of a taxpayer’s employment is not required in order for the conditions of the definition provision to be met. In Wunderlich, Justice Webb held that “new work location”, as defined in the definition of “eligible relocation”, is simply a location in Canada where the taxpayer is employed. The taxpayer does not have to show that the circumstances of his employment have changed. Justice Webb held that the reference to a “new work location” is simply a label which has no bearing on the meaning of the provision.