Global Minimum Tax Act — G-3.3 28
d’investissement ) other flow-through amounts , of an owner in respect of a qualified flow-through ownership interest for a fiscal year, means the total of the following amounts received by the owner in respect of the ownership interest in the fiscal year: (a) the tax benefits of qualified refundable tax credits and marketable transferable tax credits of the owner; (b) distributions (including returns of capital); and (c) proceeds from sales of all or part of the ownership interest. ( autres montants intermédiaires ) proportional amortization method interest means a qualified flow-through ownership interest in respect of which the owner uses the proportional amortization method for financial accounting purposes. ( participation selon la méthode d’amortissement proportionnelle ) proportional amortization method investment remaining amount , of an owner in respect of a proportional amortization method interest for a fiscal year (referred to in this definition as the “determination year”), means the amount determined by the formula A − B where A is the investment amount of the owner in respect of the interest; and B is the total of all amounts each of which is the lesser of the following amounts for the determination year or a preceding fiscal year: (a) the amount determined by the formula C + D where C is (i) in the case of the determination year, nil, and (ii) in any other case, the qualified flow-through tax benefits of the owner in respect of the interest for the fiscal year, and D is the other flow-through amounts of the owner in respect of the interest for the fiscal year, and (b) the proportional investment reduction amount of the owner in respect of the interest for the fiscal year. ( montant de l’investissement résiduel selon la méthode d’amortissement proportionnelle ) proportional investment reduction amount , of an owner in respect of a proportional amortization method interest for a fiscal year, means the amount determined by the formula A × B where A is the investment amount of the owner in respect of the interest; and B is the expected tax benefits ratio of the owner in respect of the interest for the fiscal year. ( montant de la réduction de l’investissement proportionnel ) qualified flow-through ownership interest means, subject to subsection (5), an ownership interest in a particular tax transparent entity held by a constituent entity of an MNE group directly, or indirectly through one or more other tax transparent entities that are not constituent entities of the MNE group, if (a) the assets, liabilities, income, expenses and cash flows of the particular tax transparent entity are not consolidated on a line-by-line basis in the consolidated financial statements of the ultimate parent entity of the MNE group; and (b) at the time the ownership interest was acquired by the owner, the total return to be received by the owner (including distributions, the tax benefits of tax losses and the tax benefits of qualified refundable tax credits and marketable transferable tax credits of the owner received in respect of the ownership interest, but excluding the tax benefits of tax credits other than qualified refundable tax credits and marketable transferable tax credits of the owner) from its investment in the ownership interest could not reasonably have been expected to be greater than or equal to the investment amount of the owner in respect of the ownership interest. ( titre de participation intermédiaire admissible ) qualified flow-through tax benefits , of an owner in respect of a qualified flow-through ownership interest for a fiscal year in which the ownership interest is subject to an election under subsection 18 (7), means (a) if the ownership interest is a proportional amortization method interest, the least of (i) the flow-through tax benefits of the owner in respect of the ownership interest for the fiscal year, (ii) the proportional amortization method investment remaining amount of the owner in respect of the