3 March 2011 Internal T.I. 2010-0387281I7 F - Déduction - personnel des Forces canadiennes -- summary under Paragraph 110(1)(f)

In response to a query as to whether the taxpayer is considered a member of the Canadian Forces and if the missions in which the taxpayer has participated qualify as either international operational missions or prescribed missions, CRA responded:

Under the Act, it is the responsibility of the Department of National Defence to identify international operational missions that have a risk premium of level 3 or higher. As for the missions covered for the purposes of subclause 110(1)(f)(v)(v)(A)(II), they are provided for in [Reg.] 7500 … . The Canada Revenue Agency therefore does not have the authority to make those determinations. Furthermore …, it would appear that the … operations in which the taxpayer participated are missions referred to for the purposes of subclause 110(1)(f)(v)(A)(A)(II).

… [T]he question of whether someone is a member of the Canadian Forces must be resolved in light of the relevant provisions of the National Defence Act. It provides that a member of the Canadian Forces is an officer or non-commissioned member who is a member of the Regular or Reserve Force.

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