After noting that under the then-current definition, the term "eligible apprentice" referred to an individual who is employed in a prescribed trade in Canada during the first two years of the individual's apprenticeship contract, which is registered inter alia with a province under an apprenticeship program designed to certify or license individuals in the trade, CRA stated:
In light of subsection 37(1) of the Interpretation Act, which defines the concept of year, it is our view that the term year in the phrase "first two years" must be interpreted in light of the concept of year in the Interpretation Act and extends to any 12-month period. Consequently, an industry-specific number of hours does not constitute a year for the purposes of the definition of eligible apprentice in subsection 127(9) such that the period of time an individual is an eligible apprentice cannot exceed the first two 12-month periods of their apprenticeship contract.