27 November 2000 Internal T.I. 2000-0054447 F - Interprétation installation - emploi -- summary under Clause 122.3(1)(b)(i)(B)

Before concluding that “it would be reasonable to conclude that a software development business carried on outside Canada by a specified employer can constitute an installation or engineering activity for the purposes of section 122.3,” the Directorate stated that “a particular employer that carries on a business abroad relating to the coordination and implementation of software, as well as the introduction of financial management systems, could probably successfully argue that its business relates to an installation activity for the purposes of section 122.3” and indicated that this interpretation would be supported by Gabie v. The Queen, 98 DTC 2207.