Income Tax Act — I-3.3 127
 copy of the document by which the person legally entitled to administer its affairs authorized the agreement to be made, (iii) where the transferee is a corporation and its directors are legally entitled to administer its affairs, a certified copy of their resolution authorizing the agreement to be made, and (iv) where the transferee is a corporation and its directors are not legally entitled to administer its affairs, a certified copy of the document by which the person legally entitled to administer its affairs authorized the agreement to be made; or (d) an agreement amending the agreement has been filed in accordance with subsection 127(13) and this subsection, except where subsection 127(16) applies to the original agreement. Non-arm’s length parties (16) Where a taxpayer does not deal at arm’s length with another taxpayer as a result of a transaction, event or arrangement, or a series of transactions or events, the principal purpose of which can reasonably be considered to have been to enable the taxpayers to enter into an agreement referred to in subsection 127(13), for the purpose of paragraph 127(13)(e) the least of the amounts determined under paragraphs 127(13)(a) to 127(13)(c) in respect of the agreement is deemed to be nil. Assessment (17) Notwithstanding subsections 152(4) and 152(5), such assessment of the tax, interest and penalties payable by any taxpayer in respect of any taxation year that began before the day an agreement or amended agreement is filed under subsection 127(13) or 127(20) shall be made as is necessary to take into account the agreement or the amended agreement. Reduction of qualified expenditures (18) Where on or before the filing-due date for a taxation year of a person or partnership (referred to in this subsection as the “taxpayer”) the taxpayer has received, is entitled to receive or can reasonably be expected to receive a particular amount that is government assistance, non-government assistance or a contract payment that can reasonably be considered to be in respect of scientific research and experimental development, the amount by which the particular amount exceeds all amounts applied for preceding taxation years under this subsection or subsection 127(19) or 127(20) in respect of the particular amount shall be applied to reduce the taxpayer’s qualified expenditures otherwise incurred in the year that can reasonably be considered to be in respect of the scientific research and experimental development. Reduction of qualified expenditures (19) Where on or before the filing-due date for a taxation year of a person or partnership (referred to in this subsection as the “recipient”) the recipient has received, is entitled to receive or can reasonably be expected to receive a particular amount that is government assistance, non-government assistance or a contract payment that can reasonably be considered to be in respect of scientific research and experimental development and the particular amount exceeds the total of (a) all amounts applied for preceding taxation years under this subsection or subsection 127(18) or 127(20) in respect of the particular amount, (b) the total of all amounts each of which would be a qualified expenditure that is incurred in the year by the recipient and that can reasonably be considered to be in respect of the scientific research and experimental development if subsection 127(18) did not apply to the particular amount, and (c) the total of all amounts each of which would, but for the application of this subsection to the particular amount, be a qualified expenditure (i) that was incurred by a person or partnership in a taxation year of the person or partnership that ended in the recipient’s taxation year, and (ii) that can reasonably be considered to be in respect of the scientific research and experimental development to the extent that it was performed by the person or partnership at a time when the person or partnership was not dealing at arm’s length with