Purves v. The Queen, 2005 DTC 684, 2005 TCC 290 (Informal Procedure) -- summary under Subsection 122.3(1)

The taxpayer, who lived in Windsor, Ontario, was employed by a Canadian firm that carried on the business of supplying engineering services, and as employee he provided such services on behalf of his employer to an American car manufacturer. In finding that the credit was available to the taxpayer, Bowie J. rejected the Crown's submission that because the taxpayer's employer was providing services of its personnel, and therefore was in a personnel business, it should not be characterized as being in a business with respect to engineering activities.