Before finding that the correspondent, who had received an allowance while stationed abroad, was not eligible for the overseas employment tax credit, CRA paraphrased Reg. 3400 as follows:
Section 3400 of the Regulations provides that a program will be an international development assistance program of the Government of Canada if the following two conditions are satisfied:
(1) it is an international development assistance program of the Canadian International Development Agency; and
(2) the program is financed by funds (other than development assistance loans) provided through External Affairs Vote No. 30a under Appropriation Act No. 3 of 1977-78 or by another appropriation providing for such financing.