In finding that scholarships awarded to postdoctoral fellows are ineligible for the full tax exemption for scholarships and fellowships, as they are ineligible for the education tax credit, CRA stated:
The CRA does not consider postdoctoral fellows to be students for purposes of the education tax credit. …
However, should the CRA accept the contention that a postdoctoral fellow receives a scholarship and can claim the education tax credit, it would still be of the view that the postdoctoral fellow could not claim the scholarship exemption unless the amount so received was sufficiently related to the qualifying educational program for which the education tax credit is claimed. In most cases, a postdoctoral fellow's income is not sufficiently related to a qualifying educational program.