Income Tax Act — I-3.3 89
the number of days in the taxation year, (b) that proportion of 0.69 that the number of days in the taxation year that are in 2010 is of the number of days in the taxation year, (c) that proportion of 0.70 that the number of days in the taxation year that are in 2011 is of the number of days in the taxation year, and (d) that proportion of 0.72 that the number of days in the taxation year that are after 2011 is of the number of days in the taxation year; ( facteur du taux géneral ) general rate income pool at the end of a particular taxation year, of a taxable Canadian corporation that is a Canadian-controlled private corporation or a deposit insurance corporation in the particular taxation year, is the positive or negative amount determined by the formula A – B where A is the positive or negative amount that would, before taking into consideration the specified future tax consequences for the particular taxation year, be determined by the formula C + D + E + F – G where C is the corporation’s general rate income pool at the end of its preceding taxation year, D is the amount, if any, that is the product of the corporation’s general rate factor for the particular taxation year multiplied by its adjusted taxable income for the particular taxation year, E is the total of all amounts each of which is (a) an eligible dividend received by the corporation in the particular taxation year, or (b) in the case of (i) a Canadian-controlled private corporation, (A) an amount deductible under paragraph 113(1)(a) in computing the taxable income of the corporation for the particular taxation year in respect of a dividend received on a share of the capital stock of a foreign affiliate less the amount of non-business-income tax (as defined in subsection 126(7)) paid by the corporation to the government of a country other than Canada in respect of the dividend, and (B) if an election was made by the corporation under subsection 93.4(3) for the particular taxation year, the total of the amounts deductible under paragraphs 113(1)(b) and (c) in computing the taxable income of the corporation for the year in respect of a dividend received on a share of the capital stock of a foreign affiliate to the extent that the amount was determined under paragraph 93.4(3)(b) (referred to in this clause as the “high RTF amount”) less the amount determined under clause 113(1)(c)(i)(A) in respect of the high RTF amount, and (ii) a deposit insurance corporation, (A) an amount deductible under paragraph 113(1)(a) in computing the taxable income of the corporation for the particular taxation year in respect of a dividend received on a share of the capital stock of a foreign affiliate less the amount of non-business-income tax (as defined in subsection 126(7)) paid by the corporation to the government of a country other than Canada in respect of the dividend, (B) an amount deductible under paragraph 113(1)(a.1) in computing the taxable income of the corporation for the particular taxation year in respect of a dividend received on a share of the capital stock of a foreign affiliate less the amount determined under sub-subclause 113(1)(a.1)(ii)(A)(II)1 in respect of the dividend, and (C) the total of the amounts deductible under paragraphs 113(1)(b) and (c) in computing the taxable income of the corporation for the particular taxation year in respect of a dividend received on a share of the capital stock of a foreign affiliate less the amount determined under clause 113(1)(c)(i)(A) in respect of the dividend, F is the total of all amounts determined under subsections (4) to (6) in respect of the corporation for the particular taxation year, and G is (a) unless paragraph (b) applies, the amount, if any, by which (i) the total of all amounts each of which is the amount of an eligible dividend paid by the corporation in its preceding taxation year exceeds (ii) the total of all amounts each of which is an excessive eligible dividend designation made by the corporation in i