Income Tax Act — I-3.3 (a)
st of a property, (ii) is not included in computing the income of the taxpayer for the year under paragraph 12(1)(x), and (iii) would be included in computing the income of the taxpayer for the year under paragraph 12(1)(x) if that paragraph were read without reference to its subparagraphs (vi) and (vii); and C is the total of all amounts each of which is (a) the taxpayer’s interest and financing revenues for the year, (b) an amount included under subsection 13(1) in computing the taxpayer’s income for the year, (c) in respect of the income or loss of a partnership, for a fiscal period that ends in the year, from any source or from sources in a particular place, an amount determined by the formula O × P where O is an amount that is included by the partnership under subsection 13(1) in computing its income or loss from the source, or the source in a particular place, for the fiscal period, and P is the taxpayer’s specified proportion, if the references in the definition specified proportion in subsection 248(1) to “total income or loss” were read as “income or loss from the source, or the source in a particular place”, (d) an amount included under subsection 59(1) or (3.2) or paragraph 59.1(b) in computing the taxpayer’s income for the year, (e) in the case of a corporation (i) 100/28 of the total of the amounts that would be deductible by it under subsection 126(1) from its tax for the year otherwise payable under this Part if those amounts were determined without reference to sections 123.3 and 123.4, or (ii) the amount determined by multiplying the total of the amounts that would be deductible by it under subsection 126(2) from its tax for the year otherwise payable under this Part, if those amounts were determined without reference to section 123.4, by the relevant factor for the year, (f) in the case of a trust, the amount determined by the formula Q × (1 ÷ (R × S)) where Q is the total of the amounts deductible by it under subsection 126(1) or (2) from its tax for the year otherwise payable under this Part for the year, R is the percentage (expressed as a decimal fraction) referred to in paragraph 122(1)(a) in respect of the year, and S is 1 plus the percentage (expressed as a decimal fraction) referred to in subsection 120(1) in respect of the year, (g) an amount included under section 110.5 in computing the taxpayer’s taxable income for the year, (h) an amount included under subsection 104(13) in computing the taxpayer’s income for the year, except to the extent of any portion of the amount that (i) has been designated under subsection 104(19) for the year, or (ii) gives rise to a deduction under paragraph 94.2(3)(a) in computing the foreign accrual property income for an affiliate taxation year of an entity that is a controlled foreign affiliate of the taxpayer at the end of the affiliate taxation year, (i) an amount of the taxpayer’s taxable income for the year that is not, because of an Act of Parliament, subject to tax under this Part, or (j) the amount that would be the taxpayer’s income for the year, or that would be the taxpayer’s share of the income of a partnership of which the taxpayer is a member, if the taxpayer or partnership had no income or loss other than income that can reasonably be considered to be earned by the taxpayer or the partnership in respect of activities funded by a borrowing (within the meaning of the definition exempt interest and financing expenses ) that results in exempt interest and financing expenses of the taxpayer or the partnership. ( revenu imposable rajusté )