Income Tax Act — I-3.3 34.2
d the particular year ends in (i) 2012, 100%, (ii) 2013, 85%, (iii) 2014, 65%, (iv) 2015, 45%, (v) 2016, 25%, and (vi) 2017, 0%; and (c) if the first taxation year for which the corporation has qualifying transitional income ends in 2013 and the particular year ends in (i) 2013, 85%, (ii) 2014, 65%, (iii) 2015, 45%, (iv) 2016, 25%, and (v) 2017, 0%. ( pourcentage déterminé ) Income inclusion — adjusted stub period accrual (2) Subject to subsections (5) and (9), a corporation (other than a professional corporation) shall include in computing its income for a taxation year its adjusted stub period accrual in respect of a partnership if (a) the corporation has a significant interest in the partnership at the end of the last fiscal period of the partnership that ends in the year; (b) another fiscal period of the partnership begins in the year and ends after the year; and (c) at the end of the year, the corporation is entitled to a share of an income, loss, taxable capital gain or allowable capital loss of the partnership for the fiscal period referred to in paragraph (b). Income inclusion — new partner designation (3) Subject to subsection (5), if a corporation (other than a professional corporation) becomes a member of a partnership during a fiscal period of the partnership (in this subsection referred to as the “particular period”) that begins in the corporation’s taxation year and ends after the taxation year but on or before the filing-due date for the taxation year and the corporation has a significant interest in the partnership at the end of the particular period, the corporation may include in computing its income for the taxation year the lesser of (a) the amount, if any, designated by the corporation in its return of income for the taxation year, and (b) the amount determined by the formula A × B/C where A is the corporation’s income from the partnership for the particular period (other than any amount for which a deduction is available under section 112 or 113), B is the number of days that are both in the corporation’s taxation year and the particular period, and C is the number of days in the particular period. Treatment in following year (4) If an amount was included in computing the income of a corporation in respect of a partnership for the immediately preceding taxation year under subsection (2) or (3), (a) the portion of the amount that, because of subparagraph (5)(a)(i) or (ii), was income for that preceding year is deductible in computing the income of the corporation for the current taxation year; and (b) the portion of the amount that, because of subparagraph (5)(a)(i) or (ii), was taxable capital gains for that preceding year is deemed to be an allowable capital loss of the corporation for the current taxation year from the disposition of property. Character of amounts (5) For the purposes of this Act, the following rules apply: (a) in computing the income of a corporation for a taxation year, (i) an adjusted stub period accrual included under subsection (2) in respect of a partnership for the year is deemed to be income, and taxable capital gains from the disposition of property, having the same character and to be in the same proportions as any income and taxable capital gains that were allocated by the partnership to the corporation for all fiscal periods of the partnership ending in the year, (ii) an amount included under subsection (3) in respect of a partnership for the year is deemed to be income, and taxable capital gains from the disposition of property, having the same character and to be in the same proportions as any income and taxable capital gains that were allocated by the partnership to the corporation for the particular period referred to in that subsection, (iii) an amount, a portion of which is deductible or is an allowable capital loss under subsection (4) in respect of a partnership for the year, is deemed to have the same character and to be in the same proportions as the income and tax