Words and Phrases - "an"

While resident in Canada, the taxpayer was granted rights under the employee stock option plan of his Canadian employer and further rights (the "share appreciation rights") to be paid amounts based on the appreciation in the shares of his employer over the strike price in lieu of exercising his stock option rights. Amounts paid to the taxpayer while he was a non-resident of Canada pursuant to the share appreciation rights were not exempted by Article 15 of the U.K.-Canada Convention. The presumption in s. 7(4) of the Act that the employment in issue was exercised in Canada was not incompatible with Article 15.