university

The taxpayer took some courses at the Nelson Marlborough Institute of Technology in New Zealand that would have led to a Diploma in Aviation Science (Helicopter) or a Bachelor of Commerce degree although he quit after obtaining sufficient courses to get a job as a helicopter pilot. It was found that the Institute qualified as a university given that it granted Bachelor of Commerce degree and the taxpayer's courses were creditable towards the Bachelor of Commerce degree.

In finding that an American educational institution called "Minot State University - Bottineau, which granted a two-year associate degree, with students following the two years being permitted to transfer course credits towards a bachelor degree at Minot State University, was not a "university outside Canada" for purposes of ss.118.5(1)(b) and 118.6(1)(b), Noël J.A. stated (at para. 21):