Words and Phrases - "throughout the year"

85
44
76
50
38
31
18
14
72
2
2
32
55
25
38
79
3
76
89
46
15
9
22
2

25 April 2008 External T.I. 2008-0274401E5 F - Crédit d'impôt pour enfant

meaning of "ordinarily reside" and "throughout the … year"

Regarding a query as to the meaning of "ordinarily reside" and "throughout the … year" in s. 118(1)(b.1), CRA stated:

Thomson … held that a person is ordinarily resident at the place where in the ordinary course of his life he regularly, normally or customarily lives. …

[S]ubsection 118(9.1) states that in the case of a child who in a taxation year is born, adopted or dies, the reference to “throughout the taxation year” in subparagraph 118(1)(b.1)(i) is to be read as a reference to “throughout the portion of the taxation year that is after the child’s birth or adoption or before the child’s death”.

Given this clarification, we are of the view that the expression "throughout the year" must be given its literal meaning, which implies that the conditions must be satisfied at any time during the taxation year, i.e. from January 1 to December 31 (except in the circumstances described in subsection 118(9.1)).