Income Tax Act — I-3.3 120.4
n the year; and B is the total of all amounts each of which is determined by the formula C × D/E where C is the fair market value of property contributed by the specified individual in support of a related business at the time it was contributed, D is the number of days in the year that the property (or property substituted for it) is used in support of the related business and has not directly or indirectly, in any manner whatever, been returned to the specified individual, and E is the number of days in the year. ( rendement exonéré ) source individual , in respect of a specified individual for a taxation year, means an individual (other than a trust) who, at any time in the year, is (a) resident in Canada; and (b) related to the specified individual. ( particulier source ) specified individual , for a taxation year, means an individual (other than a trust) who (a) is resident in Canada (i) in the case where the individual dies in the year, immediately before the death, and (ii) in any other case, at the end of the year; and (b) if the individual has not attained the age of 17 years before the year, has a parent resident in Canada at any time in the year. ( particulier déterminé ) split income , of a specified individual for a taxation year, means the total of all amounts (other than excluded amounts) each of which is (a) an amount required to be included in computing the individual’s income for the year (i) in respect of taxable dividends received by the individual in respect of shares of the capital stock of a corporation (other than shares of a class listed on a designated stock exchange or shares of the capital stock of a mutual fund corporation), or (ii) because of the application of section 15 in respect of the ownership by any person of shares of the capital stock of a corporation (other than shares of a class listed on a designated stock exchange), (b) a portion of an amount included because of the application of paragraph 96(1)(f) in computing the individual’s income for the year, to the extent that the portion (i) is not included in an amount described in paragraph (a), and (ii) can reasonably be considered to be income derived directly or indirectly from (A) one or more related businesses in respect of the individual for the year, or (B) the rental of property by a particular partnership or trust, if a person who is related to the individual at any time in the year (I) is actively engaged on a regular basis in the activities of the particular partnership or trust related to the rental of property, or (II) in the case of a particular partnership, has an interest in the particular partnership directly or indirectly through one or more other partnerships, (c) a portion of an amount included because of the application of subsection 104(13) or 105(2) in respect of a trust (other than a mutual fund trust or a trust that is deemed to be in existence by subsection 143(1)) in computing the individual’s income for the year, to the extent that the portion (i) is not included in an amount described in paragraph (a), and (ii) can reasonably be considered (A) to be in respect of taxable dividends received in respect of shares of the capital stock of a corporation (other than shares of a class listed on a designated stock exchange or shares of the capital stock of a mutual fund corporation), (B) to arise because of the application of section 15 in respect of the ownership by any person of shares of the capital stock of a corporation (other than shares of a class listed on a designated stock exchange), (C) to be income derived directly or indirectly from one or more related businesses in respect of the individual for the year, or (D) to be income derived from the rental of property by a particular partnership or trust, if a person who is related to the individual at any time in the year is actively engaged on a regular basis in the activities of the particular partnership or trust related to the rental of property, (d) an amount