An employee supervises three construction projects in a foreign country, one of which is partially funded by a Reg. 3400 international development assistance program.
In finding that the employee is ineligible for the OETC for the portion of employment income reasonably attributable to the two out of three projects not funded by such program, CRA stated:
[S]ince section 3400 of the Regulations does not provide for a minimum percentage of funding, a contract that is funded, even in part, by that type of program is a prescribed program of international development assistance. Finally, the wording of paragraphs 122.3(1)(c) and (d) does not allow the portion of an individual's employment income attributable to services rendered under a prescribed international development assistance program in respect of a project to be excluded from the individual's income for the year from that employment.