Income Tax Act — I-3.3 161
the year from sources in that country has been (a) transferred to Canada, (b) used by the taxpayer for any purpose whatever, other than payment of income tax to the government of that other country on income from sources in that country, or (c) disposed of by the taxpayer, and no interest is payable under this section in respect of that additional tax, or part thereof, during the period of postponement. Foreign tax credit adjustment (6.1) Notwithstanding any other provision in this section, where the tax payable under this Part by a taxpayer for a particular taxation year is increased because of (a) an adjustment of an income or profits tax payable by the taxpayer to the government of a country other than Canada or to the government of a state, province or other political subdivision of such a country, or (b) a reduction in the amount of foreign tax deductible under subsection 126(1) or (2) in computing the taxpayer’s tax otherwise payable under this Part for the particular year, as a result of the application of subsection 126(4.2) in respect of a share or debt obligation disposed of by the taxpayer in the taxation year following the particular year, no interest is payable, in respect of the increase in the taxpayer’s tax payable, for the period (c) that ends 90 days after the day on which the taxpayer is first notified of the amount of the adjustment, if paragraph (a) applies, and (d) before the date of the disposition, if paragraph (b) applies. Flow-through share renunciations (6.2) Where the tax payable under this Part by a taxpayer for a taxation year is more than it otherwise would be because of a consequence for the year described in paragraph (b) of the definition specified future tax consequence in subsection 248(1) in respect of an amount purported to be renounced in a calendar year, for the purposes of the provisions of this Act (other than this subsection) relating to interest payable under this Act, an amount equal to the additional tax payable is deemed (a) to have been paid on the taxpayer’s balance-due day for the taxation year on account of the taxpayer’s tax payable under this Part for the year; and (b) to have been refunded on April 30 of the following calendar year to the taxpayer on account of the taxpayer’s tax payable under this Part for the taxation year. Effect of carryback of loss, etc. (7) For the purpose of computing interest under subsection 161(1) or 161(2) on tax or a part of an instalment of tax for a taxation year, and for the purpose of section 163.1, (a) the tax payable under this Part and Parts I.3, VI and VI.1 by the taxpayer for the year is deemed to be the amount that it would be if the consequences of the deduction, reduction or exclusion of the following amounts were not taken into consideration: (i) any amount deducted under section 119 in respect of a disposition in a subsequent taxation year, (ii) any amount deducted under section 41 in respect of the taxpayer’s listed-personal-property loss for a subsequent taxation year, (iii) any amount excluded from the taxpayer’s income for the year by virtue of section 49 in respect of the exercise of an option in a subsequent taxation year, (iv) any amount deducted under section 118.1 in respect of a gift made in a subsequent taxation year or under section 111 in respect of a loss for a subsequent taxation year, (iv.1) any amount deducted under subsection 126(2) in respect of an unused foreign tax credit (within the meaning assigned by subsection 126(7)), or under subsection 126(2.21) or (2.22) in respect of foreign taxes paid, for a subsequent taxation year, (iv.2) any amount deducted in computing the taxpayer’s income for the year by virtue of an election in a subsequent taxation year under paragraph 164(6)(c) or 164(6)(d) by the taxpayer’s legal representative, (v) any amount deducted under subsection 127(5) in respect of property acquired or an expenditure made in a subsequent taxation year, (vi) [Repealed, 2013, c. 34, s. 318] (vii) any a