The taxpayer studied at the University of Phoenix's Edmonton campus. Little J. found that the university was an "institution in Canada" for the taxpayer's purposes under s. 118.5(1)(a), given that the taxpayer's studies occurred on a Canadian campus. She could therefore deduct tuition expenses.
Little J. pointed out, however, that the taxpayer could not deduct education tax credits, because the University of Phoenix did not qualify as a "designated educational institution" under s. 118.6.