Income Tax Act — I-3.3 18.2
 in respect of a partnership of which the taxpayer is a member that can reasonably be considered to be attributable to an amount referred to in the description of F in paragraph (h) in respect of a fiscal period of the partnership ending in another taxation year of the taxpayer, or (j) in respect of a corporation that is a controlled foreign affiliate of the taxpayer at the end of an affiliate taxation year ending in the particular year, an amount determined by the formula G × H where G is the affiliate’s relevant affiliate interest and financing expenses for the affiliate taxation year, and H is the taxpayer’s specified participating percentage in respect of the affiliate for the affiliate taxation year; and B is the total of all amounts, each of which is (a) an amount received or receivable (other than as a dividend or in respect of exempt interest and financing expenses) by the taxpayer in a year, or a gain of the taxpayer for a year, as the case may be, under or as a result of an agreement or arrangement to the extent that (i) the amount is included in computing the taxpayer’s income for the particular year, (ii) the agreement or arrangement is entered into (A) as a borrowing or other financing of the taxpayer or of a person or partnership that does not deal at arm’s length with the taxpayer, or (B) in relation to a borrowing or other financing of the taxpayer or of a person or partnership that does not deal at arm’s length with the taxpayer to hedge the cost of funding or the borrowing or other financing, (iii) the amount can reasonably be considered to reduce the cost of funding with respect to the borrowing or other financing of the taxpayer or a person or partnership that does not deal at arm’s length with the taxpayer, and (iv) the amount cannot reasonably be considered to be excluded, reduced, offset or otherwise effectively sheltered from tax under this Part because (A) an amount is deductible under any of subsections 20(11) to (12.1) and 126(1) and (2), and (B) an amount is deductible in respect of income or profits tax paid to a country other than Canada that (I) can reasonably be considered to have been paid in respect of the amount, and (II) is not a tax substantially similar to tax under subsection 212(1), or (b) in respect of the income or loss of a partnership, for a fiscal period that ends in the particular year, from any source or from sources in a particular place, an amount determined by the formula I × J where I is an amount that would be described in paragraph (a) if (i) the references to the taxpayer in that paragraph were read as references to the partnership, and (ii) the reference in subparagraph (a)(i) to “the taxpayer’s income for the particular year” were read as “the partnership’s income or loss from the source, or the source in a particular place, for a fiscal period”, and J is the taxpayer’s specified proportion, if the references in the definition specified proportion in subsection 248(1) to “total income or loss” were read as “income or loss from the source, or the source in a particular place”. ( dépenses d’intérêts et de financement ) interest and financing revenues of a taxpayer for a taxation year means the amount determined by the formula A − B where A is the total of all amounts (other than any amount included under the description of B in the definition interest and financing expenses ), each of which is (a) an amount received or receivable as, on account of, in lieu of payment or in satisfaction of, interest (other than excluded interest for the year, an amount that is deemed to be interest under subsection 137(4.1) or any amount described in any other paragraph in this definition) that is included in computing the taxpayer’s income for the year, (b) an amount that is included in computing the taxpayer’s income for the year because of subsection 12(9) or section 17.1 (other than any amount described in any other paragraph in this definition), (c) a fee or similar amount in respect of