student

The taxpayers were postdoctoral students. Woods J. found that amounts received in 2009 under a research fellowship from Parkinson Society Canada ("PSC") were indeed "fellowships" within the meaning of s. 56(1)(n).

Woods J. then found that the taxpayers were entitled to the s. 56(3) fellowship exemption. She focused on three legislative requirements:

Before going on to follow Huang in finding that post-doctoral fellowships received by the taxpayer (prior to 2010 amendments to the definition of "qualifying educational program") from McGill University qualified for the s. 56(3) scholarship exemption, Boyle J stated (at para. 19) "that in this case it appears clear that the purpose and structure of the post-doctoral fellow program was the continued training and education of the fellows within a fixed period of time following the receipt of their doctoral degree."