Income Tax Application Rules — I-3.31 26
xtinguishment of an obligation described in subsection 80.1(5) of the amended Act, and (d) in respect of which subsection 80.1(4) or (5), as the case may be, of the amended Act applies because of an election described in that subsection made by the taxpayer, shall be deemed to be the principal amount of that asset. Idem (11.2) For the purposes of computing the fair market value on December 31, 1971 of any shares owned by a taxpayer resident in Canada of the capital stock of a foreign affiliate of the taxpayer, the fair market value on that day of any asset owned by the foreign affiliate on that day (a) that was subsequently acquired by the taxpayer from the foreign affiliate as described in paragraph 80.1(6)(a) or (b) of the amended Act, and (b) in respect of which subsection 80.1(1) of the amended Act applies because of an election described in subsection 80.1(6) of that Act made by the taxpayer, shall be deemed to be the principal amount of that asset, Definitions (12) In this section, amortized cost to a taxpayer of any obligation on January 1, 1972 means (a) the principal amount of the obligation, if its actual cost to the taxpayer was less than 100% but not less than 95% of that principal amount and the obligation was issued before November 8, 1969, (b) the actual cost to the taxpayer of the obligation, if the actual cost to the taxpayer thereof was less than 105% but not less than 100% of the principal amount thereof, and (c) in any other case, the actual cost to the taxpayer of the obligation, plus that proportion of the discount or minus that proportion of the premium, as the case may be, in respect thereof that (i) the number of full months in the period commencing with the day the taxpayer last acquired the obligation and ending with valuation day, is of (ii) the number of full months in the period commencing with the day the taxpayer last acquired the obligation and ending with the date of its maturity; ( coût amorti ) capital property of a taxpayer means any depreciable property of the taxpayer, and any property (other than depreciable property) any gain or loss from the disposition of which would, if the property were disposed of after 1971, be a capital gain or a capital loss, as the case may be, of the taxpayer; ( immobilisation ) discount in respect of any obligation owned by a taxpayer means the amount, if any, by which the principal amount thereof exceeds its actual cost to the taxpayer, determined without reference to subsection (3); ( escompte ) eligible capital property of a taxpayer means any property, ½ of any amount payable to the taxpayer as consideration for the disposition of which would, if the property were disposed of after 1971, be eligible capital amount in respect of business within the meaning assigned by subsection 14(1) of the amended Act; ( immobilisation admissible ) obligation means a bond, debenture, bill, note, mortgage, hypothecary claim or agreement of sale; ( obligation ) premium in respect of any obligation owned by a taxpayer means the amount, if any, by which its actual cost to the taxpayer determined without reference to subsection (3) exceeds the principal amount thereof; ( primes ) tax equity of a partnership at any particular time means the amount, if any, by which the total of all amounts each of which is (a) the amount of any money of the partnership on hand at the beginning of its first fiscal period ending after 1971, (b) the cost amount to the partnership, at the beginning of that fiscal period, of any partnership property other than capital property or eligible capital property, (c) an amount in respect of any property (other than depreciable property) that was, at the beginning of that fiscal period, capital property of the partnership, equal to, (i) where the property was disposed of before 1972, the proceeds of disposition thereof, (ii) where the property was disposed of after 1971 and before the particular time, the amount determined under this section to be its cost