Income Tax Act — I-3.3 137.1
positors of a member institution in financial difficulty, (C) to lend money to a subsidiary wholly-owned corporation of the taxpayer where the subsidiary is deemed by subsection 137.1(5.1) to be a deposit insurance corporation, (D) to acquire property from a member institution in financial difficulty, or (E) to acquire shares of the capital stock of a member institution in financial difficulty, or (ii) an amount paid by the taxpayer in the year pursuant to a legal obligation to pay interest on an amount that would be deductible under subparagraph 137.1(3)(f)(i) if it were paid in the year. Limitation on deduction (4) No deduction shall be made in computing the income for a taxation year of a taxpayer that is a deposit insurance corporation in respect of (a) any grant, subsidy or other assistance to member institutions provided by it; (b) an amount equal to the amount, if any, by which the amount paid or payable by it to acquire property exceeds the fair market value of the property at the time it was so acquired; (c) any amounts paid to its member institutions as allocations in proportion to any amounts described in subsection 137.1(2); (d) any amount paid by it to another deposit insurance corporation that is, because of paragraph (2)(b), not included in computing the income of that other deposit insurance corporation; or (e) any amount that may otherwise be deductible under paragraph 20(1)(p) in respect of debts owing to it by any of its member institutions that has not been included in computing its income for the year or a preceding taxation year. Definitions (5) In this section, deposit insurance corporation means (a) a corporation that was incorporated by or under a law of Canada or a province respecting the establishment of a stabilization fund or board if (i) it was incorporated primarily (A) to provide or administer a stabilization, liquidity or mutual aid fund for credit unions, and (B) to assist in the payment of any losses suffered by members of credit unions in liquidation, and (ii) throughout any taxation year in respect of which the expression is being applied, (A) it was a Canadian corporation, and (B) the cost amount to the corporation of its investment property was at least 50% of the cost amount to it of all its property (other than a debt obligation of, or a share of the capital stock of, a member institution issued by the member institution at a time when it was in financial difficulty, or (b) a corporation incorporated by the Canada Deposit Insurance Corporation Act ; ( compagnie d’assurance-dépôts ) investment property means (a) bonds, debentures, mortgages, hypothecary claims, notes or other similar obligations (i) of or guaranteed by the Government of Canada, (ii) of the government of a province or an agent thereof, (iii) of a municipality in Canada or a municipal or public body performing a function of government in Canada, (iv) of a corporation, commission or association not less than 90% of the shares or capital of which is owned by Her Majesty in right of a province or by a Canadian municipality, or of a subsidiary wholly-owned corporation that is subsidiary to such a corporation, commission or association, or (v) of an educational institution or a hospital if repayment of the principal amount thereof and payment of the interest thereon is to be made, or is guaranteed, assured or otherwise specifically provided for or secured by the government of a province, (b) any deposits, deposit certificates or guaranteed investment certificates with (i) a bank, (ii) a corporation licensed or otherwise authorized under the laws of Canada or a province to carry on in Canada the business of offering to the public its services as trustee, or (iii) a credit union or central that is a member of the Canadian Payments Association or a credit union that is a shareholder or member of a central that is a member of the Canadian Payments Association, (c) any money of the corporation, and (d) in relation to a particular de