Income Tax Regulations — (a)
hybrid underlying tax , of a foreign affiliate (in this definition referred to as the “subject affiliate”) of a corporation in respect of the corporation, at any particular time, means the amount determined by the following formula in respect of the period that begins with the later of the following times and that ends with the particular time: (a) the first day of the taxation year of the subject affiliate in which it last became a foreign affiliate of the corporation, and (b) the last time for which the opening hybrid underlying tax of the subject affiliate in respect of the corporation was required to be determined under section 5905 A – B where A is the total of all amounts, in respect of the period, each of which is (i) the opening hybrid underlying tax, if any, of the subject affiliate in respect of the corporation as determined under section 5905, at the time established in paragraph (b), (ii) the portion of any income or profits tax paid to the government of a country by the subject affiliate that can reasonably be regarded as having been paid in respect of any amount referred to in subparagraph (ii) or (iv) of the description of A in the definition hybrid surplus , (iii) the total of all amounts each of which is an amount determined by the formula C × D ÷ E where C is the amount that was prescribed under paragraph 5900(1)(c.1) to have been the foreign tax applicable to the portion (referred to in this subparagraph as the “relevant portion”) of a dividend received in the period and before the particular time by the subject affiliate from another foreign affiliate of the corporation (including, for greater certainty, a dividend deemed under subsection 5905(7) to have been received by the subject affiliate) that was prescribed under paragraph 5900(1)(a.1) to have been paid out of the payer affiliate’s hybrid surplus in respect of the corporation, D is the amount included under subparagraph (iv) of the description of A in the definition hybrid surplus , in respect of the relevant portion of the dividend received, in computing the subject affiliate’s hybrid surplus, and E is the relevant portion of the dividend received, or (iv) the amount by which the subject affiliate’s hybrid underlying tax is required to be increased in the period and before the particular time under subsection (1.092), (1.1) or (1.2), B is the total of those of the following amounts that apply in respect of the period: (i) the portion of any income or profits tax refunded by the government of a country to the subject affiliate that can reasonably be regarded as having been refunded in respect of an amount referred to in subparagraph (ii) or (iii) of the description of B in the definition hybrid surplus , (ii) the hybrid underlying tax applicable to any whole dividend paid by the subject affiliate in the period and before the particular time deemed under paragraph 5901(1)(a.1) or, if subsection 5901(1.1) applied to the whole dividend, paragraph 5901(1)(b) to have been paid out of the subject affiliate’s hybrid surplus in respect of the corporation before that time, (iii) each amount that is required under section 5902 to be included under this subparagraph in the period and before the particular time, or (iv) the amount by which the subject affiliate’s hybrid underlying tax is required to be decreased in the period and before the particular time under subsection (1.092), (1.1) or (1.2); ( montant intrinsèque d’impôt hybride )