28 June 2010 External T.I. 2010-0361561E5 F - Programme d'aide au développement international -- summary under Subparagraph 6(1)(b)(iii)

After finding that the correspondent, who had received an allowance while stationed abroad in connection with a program that was funded as an international development assistance program (and who very well may have been a Canadian resident under ordinary jurisprudential principles), was not eligible for the overseas employment tax credit, CRA stated:

However, subparagraph 6(1)(b)(iii) provides that representation or other special allowances received by a person in respect of a period of absence from Canada will not be included in computing the person's income if, among other things, paragraph 250(1)(d) applies to the person. …

Consequently, to the extent that you resided in Canada at any time during the 3-month period before your start date … the allowance … that you receive while posted in that country is not required to be included in computing your income for the year in which you receive it.

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