| August 20, 1990 | |
| Assessing and Enquiries Directorate | Business and General |
| Enquiries and Taxpayer | Division |
| Assistance Division | A. Humenuk |
| 957-2135 | |
| Tom Kissner | |
| Acting Chief | 901501 |
| EACC9296 |
SUBJECT: Education Tax Credit
We are replying to your memorandum of July 5, 1990, concerning the calculation of the education tax credit available under subsection 118.6(2) of the Act.
You have asked whether a month in which a student writes an examination but does not attend lectures or other classroom activities would qualify as a month for item B of the formula in subsection 118.6(2). In particular, you refer to both the month at the end of a course in which a final examination is customarily written as well as the month in which a supplementary examination may be written for those students unsuccessful on the first try.
In our view, a month in which an examination is written and which there is no formal instruction or classroom activity may qualify as a month in which the student is a full-time attendance at a designated educational institution provided the examination is an integral part of the course of study. Thus, the month in which a mandatory final examination is held would count towards the total months eligible for the education tax credit provided the student otherwise qualified for the credit.
However, it is our understanding that supplemental examinations for students who are unsuccessful or who wish to improve their grade on a particular course are not integral to the course. Accordingly, it is our view that a student would not ordinarily be considered to be in full-time attendance for a month in which a supplemental examination is written.
Yours truly,
B.W. DathDirectorBusiness and General DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch