Excise Tax Act — E-15 172.1
spect of the pension plan and the participating province for the particular fiscal year, and H is the master pension factor determined for E; and (d) for each pension plan in the master pension group, the specified pension entity of the pension plan is deemed for the purpose of determining an input tax credit of the specified pension entity under this Part and for the purposes of sections 232.01, 232.02 and 261.01, (i) to have received a supply of the specified resource or part on the last day of the particular fiscal year, (ii) to have paid tax in respect of that supply on that day equal to the amount determined by the formula A − B where A is (A) if the specified pension entity is a selected listed financial institution on that day, the amount determined for the pension plan under the description of A in paragraph (c), and (B) in any other case, the amount of tax determined for the pension plan under paragraph (c), and B is the total of all amounts, each of which is a part of the amount determined for A (A) that is not included in determining the person’s net tax for the reporting period that includes the last day of the particular fiscal year, or (B) that the person has recovered or is entitled to recover by way of rebate, refund or remission, or otherwise, under this or any other Act of Parliament, and (iii) to have acquired the specified resource or part for consumption, use or supply in the course of its commercial activities to the same extent that the specified resource or part was acquired by the person for the purpose of making a supply of the specified resource or part to the master pension entity for consumption, use or supply by the master pension entity in the course of pension activities of the master pension entity that are commercial activities of the master pension entity. Consumption or use of employer resource for supply (6) If a person is both a registrant and a participating employer of a pension plan at any time in a particular fiscal year of the person and is not a selected qualifying employer of the pension plan at that time, if the person consumes or uses at that time an employer resource of the person for the purpose of making a supply of property or a service (in this subsection referred to as the “pension supply”) to a pension entity of the pension plan for consumption, use or supply by the pension entity in the course of pension activities in respect of the pension plan and if the employer resource is not an excluded resource of the person in respect of the pension plan, the following rules apply: (a) for the purposes of this Part, the person is deemed to have made a taxable supply of the employer resource (in this subsection referred to as the “employer resource supply”) on the last day of the particular fiscal year; (b) for the purposes of this Part, tax in respect of the employer resource supply is deemed to have become payable on the last day of the particular fiscal year and the person is deemed to have collected that tax on that day; (c) for the purposes of this Part, the tax referred to in paragraph (b) is deemed to be equal to the amount determined by the formula A + B where A is the amount determined by the formula C × D where C is (i) if the employer resource was consumed by the person during the particular fiscal year for the purpose of making the pension supply, the product obtained when the fair market value of the employer resource at the time the person began consuming it in the particular fiscal year is multiplied by the extent to which that consumption (expressed as a percentage of the total consumption of the employer resource by the person during the particular fiscal year) occurred when the person was both a registrant and a participating employer of the pension plan, or (ii) otherwise, the product obtained when the fair market value of the use of the employer resource during the particular fiscal year as determined on the last day of the particular fiscal year is multiplied by