Income Tax Act — I-3.3 18.2
other than any portion of that amount that is described in paragraph (d) of the description of A in the definition interest and financing expenses , (d) in respect of the income or loss of a partnership, for a fiscal period that ends in the year, from any source or from sources in a particular place, an amount determined by the formula F × G − H where F is the total of all amounts, each of which is an amount deducted by the partnership under paragraph 20(1)(a) or subsection 20(16) in computing its income or loss from the source, or the source in a particular place, for the fiscal period, other than any portion of that amount that is described in subparagraph (c)(ii) of the description of A in the definition interest and financing expenses , G 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”, and H is the portion of an amount referred to in the description of F that can reasonably be considered to not be deductible in computing the taxpayer’s income for the year, or to not be included in computing the taxpayer’s non-capital loss for the year, because of subsection 96(2.1), (e) the portion of an amount deducted under paragraph 111(1)(e) for the year, 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 H in paragraph (d) in respect of a fiscal period of the partnership ending in a preceding taxation year of the taxpayer, (f) an amount deducted by the taxpayer under paragraph 110(1)(k) in computing its taxable income for the year, (g) an amount deducted by the taxpayer under subsection 104(6) in computing its income for the year, except to the extent of any portion of the amount that (i) has been designated under subsection 104(19) for the year, or (ii) is attributable to an amount that would, in the absence of subsection (2), have been deductible in computing the taxpayer’s income for the year, (h) an amount determined by the formula I × J ÷ K where I is the amount deducted by the taxpayer under paragraph 111(1)(a) in computing its taxable income for the year, in respect of the taxpayer’s non-capital loss (other than a specified pre-regime loss of the taxpayer in respect of the year) for another taxation year (referred to in this paragraph as the “taxpayer loss year”), J is the lesser of (i) the non-capital loss for the taxpayer loss year, and (ii) the amount determined by the formula W − X − Y where W is the total of all amounts, each of which is an amount that is (A) the interest and financing expenses of the taxpayer for the taxpayer loss year, determined without regard to any amount or portion of an amount that is not deductible because of subsection (2) or clause 95(2)(f.11)(ii)(D), (B) described in any of paragraphs (b) to (g) or (j) to (m) of the description of B for the taxpayer loss year, or (C) deducted by the taxpayer under paragraph 111(1)(a.1) in computing its taxable income for the taxpayer loss year, X is the total of all amounts, each of which is an amount (A) described in any of paragraphs (a) to (f), (h) or (j) of the description of C for the taxpayer loss year, or (B) included in the income of the taxpayer for the taxpayer loss year by reason of paragraph 12(1)(l.2), and Y is the total of all amounts, each of which is an amount determined by the formula Z × Z.1 ÷ Z.2 where Z is the lesser of (A) the foreign accrual property loss, for an affiliate taxation year, of a corporation (referred to throughout the description of Y as the “affiliate”) that, at the end of the affiliate taxation year, is a controlled foreign affiliate of the taxpayer, or is a controlled foreign affiliate of a partnership of which the taxpayer or a controlled foreign affiliate of the taxpayer is a member at any time, and (B) the amount by which the affiliat