Income Tax Act — I-3.3 104
 (21.21)) that were disposed of by the trust on or after June 25, 2024 and before 2025; and C is, if the designation year of the trust ends on or after June 25, 2024 and before 2025, the amount that would be determined in respect of the trust for the designation year under paragraph 3(b) in respect of capital gains and capital losses if the only properties referred to in that paragraph were qualified small business corporation shares (to the extent that the amount is not included in computing the amount designated under subsection (21.21)). Trusts to designate amounts — 2024 (21.24) A trust shall determine and designate, in its return of income under this Part for a designation year of the trust, the amount that is determined under subsection (21.23) to be the beneficiary’s taxable capital gain from the disposition on or after June 25, 2024 and before 2025 of a qualified small business corporation share (to the extent that the amount is not included in computing the amount designated under subsection (21.21)) of the beneficiary. Net taxable capital gains of trust determined (21.3) For the purposes of this section, the net taxable capital gains of a trust for a taxation year is the amount, if any, determined by the formula A + B – C – D where A is the total of all amounts each of which is a taxable capital gain of the trust for the year from the disposition of a capital property that was held by the trust immediately before the disposition, B is the total of all amounts each of which is deemed by subsection (21) to be a taxable capital gain of the trust for the year, C is the total of all amounts each of which is an allowable capital loss (other than an allowable business investment loss) of the trust for the year from the disposition of a capital property, and D is the amount, if any, deducted under paragraph 111(1)(b) in computing the trust’s taxable income for the year. (21.4) to (21.7) [Repealed, 2013, c. 34, s. 231] Designation in respect of foreign source income (22) For the purposes of this subsection, subsection (22.1) and section 126, an amount in respect of a trust’s income for a particular taxation year of the trust from a source in a country other than Canada is deemed to be income of a taxpayer, for the taxation year of the taxpayer in which the particular taxation year ends, from that source if (a) the amount (i) is designated by the trust, in respect of the taxpayer, in the trust’s return of income under this Part for the particular taxation year, and (ii) may reasonably be considered (having regard to all the circumstances including the terms and conditions of the trust) to be part of the amount that, because of paragraph (13)(a) or subsection (14), was included in computing the income for that taxation year of the taxpayer; (b) the taxpayer is in the particular taxation year a beneficiary under the trust; (c) the trust is, throughout the particular taxation year, resident in Canada; and (d) the total of all amounts each of which is an amount designated, under this subsection in respect of that source, by the trust in respect of a beneficiary under the trust in the trust’s return of income under this Part for the particular taxation year is not greater than the trust’s income for the particular taxation year from that source. Foreign tax deemed paid by beneficiary (22.1) Where a taxpayer is a beneficiary under a trust, for the purposes of this subsection and section 126, the taxpayer shall be deemed to have paid as business-income tax or non-business-income tax, as the case may be, for a particular taxation year in respect of a source the amount determined by the formula A × B/C where A is the amount that, but for subsection 104(22.3), would be the business-income tax or non-business-income tax, as the case may be, paid by the trust in respect of the source for a taxation year (in this subsection referred to as “that year”) of the trust that ends in the particular year; B is the amount deemed, because of a desig