Zailo v. The Queen, 2014 DTC 1087 [at at 3128], 2014 TCC 60 (Informal Procedure) -- summary under Subsection 118.5(1)

By services, 28 November, 2015

The taxpayer enrolled in an audio engineering program that could lead either to a certificate or to an associate's degree - although it could also lead to a bachelor's degree if the student combined it with a musical performance program. Rossiter ACJ found that the taxpayer was ineligible for a tuition credit, as Klassen establishes that "degree" means at least a bachelor's degree. Rossiter ACJ stated (at para. 7):

[W]hy would courses leading to an associate's degree, which could in fact be included as part of the qualification to a bachelor's degree, not be eligible for a tuition credit? ... The answer is that, as per the Appellant's testimony, these courses were used towards a certificate program and not towards a bachelor's degree.

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undergrad courses outside Canada ineligible when taken for a certificate rather than a bachelor's degree
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