CRA considers that the EU does not qualify as a state government for FTC purposes

CRA does not consider that taxes withheld by an EU organization, on pensions paid by it to a former employee who now has retired to Canada, are eligible for a foreign tax credit. The EU "is an international organization and … would not be considered a government of a country other than Canada," whereas s. 126(1) requires that the tax be paid to such a government. (CRA did not explicitly address a potential argument that the EU is a collection of governments of countries other than Canada so that, on a look through basis and reading s. 126(1) in the plural, the credit is available - although it likely would not have been receptive.)

The credit under s. 126(3) for taxes paid on income from employment with a qualifying international organization such as the EU also is not available because this instead is pension income.

Neal Armstrong. Summaries of 30 October 2014 T.I. 2013-0500491E5 under s. 126(1), s. 126(3) and s. 110(1)(f)(i).