Income Tax Act — I-3.3 18.4
 the formula (A − C − D) × G ÷ H where G is the total of all amounts, each of which is an amount that (i) meets the following conditions: (A) is repaid or repayable in respect of income or profits tax paid or payable by the entity to the government of a country other than Canada in respect of the relevant foreign income or profits for the year, and (B) is not repaid or repayable because a loss is used to reduce or offset the relevant foreign income or profits for the year, or (ii) is paid or payable in respect of a credit that can reasonably be considered to reduce or offset, directly or indirectly, the income or profits tax referred to in clause (i)(A), and H is the total amount of the income or profits tax referred to in clause (i)(A) of the description of G; and F is the amount determined by the formula (A − C − D − E) × (1 − I ÷ J) where I is the rate at which the income or profits tax referred to in clause (i)(A) in the description of G is charged in respect of the relevant amount, and J is the highest rate at which an income or profits tax imposed by the government of the country is charged in respect of an amount of income in respect of a financial instrument. ( revenu ordinaire étranger ) foreign taxation year of an entity means the period for which the accounts of the entity have been ordinarily made up for the purpose of computing relevant foreign income or profits of the entity, but no such period may exceed 53 weeks. ( année d’imposition étrangère ) hybrid mismatch amount , in respect of a payment, means (a) if the payment arises under a hybrid financial instrument arrangement, the amount of the hybrid financial instrument mismatch in respect of the payment; (b) if the payment arises under a hybrid transfer arrangement, the amount of the hybrid transfer mismatch in respect of the payment; or (c) if the payment arises under a substitute payment arrangement, the amount of the substitute payment mismatch in respect of the payment. ( montant de l’asymétrie hybride ) hybrid mismatch arrangement under which a payment arises means (a) a hybrid financial instrument arrangement under which the payment arises; (b) a hybrid transfer arrangement under which the payment arises; or (c) a substitute payment arrangement under which the payment arises. ( dispositif hybride ) payer of a payment includes any entity that has an obligation to pay, credit or confer, either immediately or in the future and either absolutely or contingently, the payment to an entity. ( payeur ) payment includes any amount or benefit that any entity has an obligation to pay, credit or confer, either immediately or in the future and either absolutely or contingently, to an entity. ( paiement ) recipient of a payment includes any entity that has an entitlement to be paid, credited or conferred, either immediately or in the future and either absolutely or contingently, the payment by an entity. ( bénéficiaire ) relevant foreign income or profits of an entity means income or profits in respect of which the entity is subject to an income or profits tax that is imposed by the government of a country other than Canada. ( revenus ou bénéfices étrangers pertinents ) specified entity , in respect of another entity at any time, means a particular entity if, taking into consideration the rules in subsection (17), (a) the particular entity at that time, either alone or together with entities with whom the particular entity does not deal at arm’s length, owns directly or indirectly equity interests in the other entity that (i) provide 25% or more of the votes that could be cast at an annual meeting of the shareholders, if the other entity is a corporation, or (ii) have 25% or more of the fair market value of all equity interests in the other entity; (b) the condition in paragraph (a) would be satisfied if the references in that paragraph to “particular entity” were read as references to “other entity” and the references to “other entity” were read as references to “part