Income Tax Act — I-3.3 248
 larger obligation was issued that relates to that part. Limitation respecting inclusions, deductions and tax credits (28) Unless a contrary intention is evident, no provision of this Act shall be read or construed (a) to require the inclusion or permit the deduction, either directly or indirectly, in computing a taxpayer’s income, taxable income or taxable income earned in Canada, for a taxation year or in computing a taxpayer’s income or loss for a taxation year from a particular source or from sources in a particular place, of any amount to the extent that the amount has already been directly or indirectly included or deducted, as the case may be, in computing such income, taxable income, taxable income earned in Canada or loss, for the year or any preceding taxation year; (b) to permit the deduction, either directly or indirectly, in computing a taxpayer’s tax payable under any Part of this Act for a taxation year of any amount to the extent that the amount has already been directly or indirectly deducted in computing such tax payable for the year or any preceding taxation year; or (c) to consider an amount to have been paid on account of a taxpayer’s tax payable under any Part of this Act for a taxation year to the extent that the amount has already been considered to have been paid on account of such tax payable for the year or any preceding taxation year. Farming or fishing business (29) For the purposes of subsection 40(1.1) and sections 70, 73 and 110.6, if at any time a person or partnership carries on a farming business and a fishing business, a property used at that time principally in a combination of the activities of the farming business and the fishing business is deemed to be used at that time principally in the course of carrying on a farming or fishing business. Intention to give (30) The existence of an amount of an advantage in respect of a transfer of property does not in and by itself disqualify the transfer from being a gift to a qualified donee if (a) the amount of the advantage does not exceed 80% of the fair market value of the transferred property; or (b) the transferor of the property establishes to the satisfaction of the Minister that the transfer was made with the intention to make a gift. Eligible amount of gift or monetary contribution (31) The eligible amount of a gift or monetary contribution is the amount by which the fair market value of the property that is the subject of the gift or monetary contribution exceeds the amount of the advantage, if any, in respect of the gift or monetary contribution. Amount of advantage (32) The amount of the advantage in respect of a gift or monetary contribution by a taxpayer is the total of (a) the total of all amounts, other than an amount referred to in paragraph (b), each of which is the value, at the time the gift or monetary contribution is made, of any property, service, compensation, use or other benefit that the taxpayer, or a person or partnership who does not deal at arm’s length with the taxpayer, has received, obtained or enjoyed, or is entitled, either immediately or in the future and either absolutely or contingently, to receive, obtain, or enjoy (i) that is consideration for the gift or monetary contribution, (ii) that is in gratitude for the gift or monetary contribution, or (iii) that is in any other way related to the gift or monetary contribution, and (b) the limited-recourse debt, determined under subsection 143.2(6.1), in respect of the gift or monetary contribution at the time the gift or monetary contribution is made. Cost of property acquired by donor (33) The cost to a taxpayer of a property, acquired by the taxpayer in circumstances where subsection (32) applies to include the value of the property in computing the amount of the advantage in respect of a gift or monetary contribution, is equal to the fair market value of the property at the time the gift or monetary contribution is made. Repayment of limited-recourse debt (34) If