Income Tax Act — I-3.3 219
Additional tax 219 (1) Every corporation that is non-resident in a taxation year shall, on or before its balance-due day for the year, pay a tax under this Part for the year equal to 25% of the amount, if any, by which the total of (a) the corporation’s taxable income earned in Canada for the year (in this subsection referred to as the corporation’s “base amount”), (b) the amount deducted because of section 112 and paragraph 115(1)(e) in computing the corporation’s base amount, (c) [Repealed, 2003, c. 28, s. 17] (d) the amount, if any, by which the total of all amounts each of which is a taxable capital gain of the corporation for the year from a disposition of a taxable Canadian property exceeds the total of all amounts each of which is (i) an allowable capital loss of the corporation for the year from a disposition of a taxable Canadian property, or (ii) an amount deductible because of paragraphs 111(1)(b) and 115(1)(d) in computing the corporation’s base amount, (e) the total of all amounts each of which is an amount in respect of a grant or credit that (i) can reasonably be considered to have been received by the corporation in the year as a reimbursement or repayment of, or as indemnification or compensation for, an amount deducted because of paragraph (j), as it read in its application to the 1995 taxation year, in computing the amount determined under this subsection for a preceding taxation year that began before 1996, and (ii) was not included in computing the corporation’s base amount for any taxation year, (f) where, at any time in the year, the corporation has made one or more dispositions described in paragraph 219(219)(l) of qualified property, the total of all amounts each of which is an amount in respect of one of those dispositions equal to the amount, if any, by which the fair market value of the qualified property at the time of the disposition exceeds the corporation’s proceeds of disposition of the property, and (g) the amount, if any, claimed for the immediately preceding taxation year under paragraph 219(1)(j) by the corporation, exceeds the total of (h) that proportion of the total of (i) the total of the taxes payable under Parts I, I.3 and VI for the year by the corporation, determined without reference to subsection 219(1.1), and (ii) the total of the income taxes payable to the government of a province for the year by the corporation, determined without reference to subsection 219(1.1), that the corporation’s base amount is of the amount that would, if this Act were read without reference to subsection 219(1.1), be the corporation’s base amount, (i) the total of all amounts each of which is the amount of interest or a penalty paid by the corporation in the year (i) under this Act, or (ii) on or in respect of an income tax payable by it to the government of a province under a law of the province relating to income tax, to the extent that the interest or penalty was not deductible in computing its base amount for any taxation year, (j) where the corporation was carrying on business in Canada at the end of the year, the amount claimed by the corporation for the year, not exceeding the amount prescribed to be its allowance for the year in respect of its investment in property in Canada, and (k) [Repealed, 2003, c. 28, s. 17] (l) where the corporation has at any time in the year disposed of property (in this paragraph and paragraph 219(1)(f) referred to as “qualified property”) used by it immediately before that time for the purpose of gaining or producing income from a business carried on by it in Canada to a Canadian corporation (in this paragraph referred to as the “purchaser corporation”) that was, immediately after the disposition, a qualified related corporation of the corporation for consideration that includes a share of the capital stock of the purchaser corporation, the total of all amounts each of which is an amount in respect of a disposition in the year of a qualified property equal to the a