Income Tax Act — I-3.3 126
 in respect of a taxpayer’s unused foreign tax credit in respect of a country for a taxation year may be claimed under paragraph (2)(a) in computing the taxpayer’s tax payable under this Part for a particular taxation year only to the extent that it exceeds the aggregate of all amounts each of which is the amount that may reasonably be considered to have been claimed in respect of that unused foreign tax credit in computing the taxpayer’s tax payable under this Part for a taxation year preceding the particular taxation year. Employees of international organizations (3) Where an individual is resident in Canada at any time in a taxation year, there may be deducted from the individual’s tax for the year otherwise payable under this Part an amount equal to that proportion of the tax for the year otherwise payable under this Part by the individual that (a) the individual’s income (i) for the year, if the individual is resident in Canada throughout the year, and (ii) for the part of the year throughout which the individual was resident in Canada, if the individual is non-resident at any time in the year, from employment with an international organization (other than a prescribed international organization), as defined for the purposes of section 2 of the Foreign Missions and International Organizations Act is of (b) the amount, if any, by which (i) if the taxpayer is resident in Canada throughout the year, the taxpayer’s income for the year computed without reference to paragraph 20(1)(ww), and (ii) if the taxpayer is non-resident at any time in the year, the amount determined under paragraph 114(a) in respect of the taxpayer for the year exceeds (iii) the total of all amounts each of which is an amount deducted under section 110.6, 110.61 or 110.62 or paragraph 111(1)(b), or deductible under any of paragraphs 110(1)(d) to (d.3), (f) and (g), in computing the taxpayer’s taxable income for the year, except that the amount deductible under this subsection in computing the individual’s tax payable under this Part for the year may not exceed that proportion of the total of all amounts each of which is an amount paid by the individual to the organization as a levy (the proceeds of which are used to defray expenses of the organization), computed by reference to the remuneration received by the individual in the year from the organization in a manner similar to the manner in which income tax is computed, that (c) the individual’s income for the year from employment with the organization is of (d) the amount that would be the individual’s income for the year from employment with the organization if this Act were read without reference to paragraph 81(1)(a). Portion of foreign tax not included (4) For the purposes of this Act, an income or profits tax paid by a person resident in Canada to the government of a country other than Canada does not include a tax, or that portion of a tax, imposed by that government that would not be imposed if the person were not entitled under section 113 or this section to a deduction in respect of the tax or that portion of the tax. No economic profit (4.1) If a taxpayer acquires a property, other than a capital property, at any time after February 23, 1998 and it is reasonable to expect at that time that the taxpayer will not realize an economic profit in respect of the property for the period that begins at that time and ends when the taxpayer next disposes of the property, the total amount of all income or profits taxes (referred to as the “foreign tax” for the purpose of subsection 20(12.1)) in respect of the property for the period, and in respect of related transactions, paid by the taxpayer for any year to the government of any country other than Canada, is not included in computing the taxpayer’s business-income tax or non-business-income tax for any taxation year. Denial of foreign tax credit (4.11) If a taxpayer is a member of a partnership, any income or profits tax paid to the government of a part