The taxpayer, who had been employed as a temporary lecturer at a University Department, was hired to work as a professor at the Department upon her completion of doctoral studies at a US university and was paid by the Department various of the expenses incurred by her in connection with such studies including the tuition fees of the US university.
CRA found that, given that she entered into the agreement while she was employed as a temporary lecturer with the Department, the tuition reimbursement amounts (if a benefit from employment, which the Directorate went on to find was not the case) were employment income pursuant to s. 6(3) and were excluded from treatment as a scholarship under s. 56(1)(n).