18 April 2005 External T.I. 2004-0096231E5 F - Déduction de l'impôt payable - emploi à l'étranger -- summary under Paragraph 122.3(1)(a)

The taxpayer, a Canadian resident, ceased employment abroad by his Canadian employer in 2001 and was paid a separation allowance in 2002. CRA indicated that because the separation allowance (even if it was employment income rather than a retiring allowance) would have been employment income in 2002 (when he was no longer employed abroad) rather than in 2001, it could not qualify for the deduction under s. 122.3.