Before finding that the correspondent, who had received an allowance while stationed abroad, was not eligible for the overseas employment tax credit, CRA paraphrased Reg. 3400 as follows:
Section 3400 of the Regulations provides that a program will be an international development assistance program of the Government of Canada if the following two conditions are satisfied:
(1) it is an international development assistance program of the Canadian International Development Agency; and
(2) the program is financed by funds (other than development assistance loans) provided through External Affairs Vote No. 30a under Appropriation Act No. 3 of 1977-78 or by another appropriation providing for such financing.
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|Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(b) - Subparagraph 6(1)(b)(iii)||ordinary resident apparently eligible for the exclusion on overseas posting re international aid program||151|
10 June 1991 Memorandum (Tax Window, No. 4, p. 31, ¶1288)
Any program that receives CIDA funding by way of a grant will be a PIDAP irrespective of the size of such funding. A CIDA project which is technically a PIDAP (i.e., funded by way of grant) will not be treated as such if the funding agreement was initially signed prior to April 1, 1986 as a loan agreement, notwithstanding that the arrangements may even be renegotiated after March 31, 1986 as a grant agreement.