Excise Tax Act — E-15 172.1
that the employer resource is an excluded resource of the person in respect of any pension plan in the master pension group, if the pension activities relate exclusively to the establishment, management or administration of the master pension entity or the management or administration of assets held by the master pension entity and if neither of subsections (6) and (6.1) applies to that consumption or use, the following rules apply: (a) for the purposes of this Part, the person is deemed to have made a taxable supply of the employer resource (in this subsection referred to as the “employer resource supply”) on the last day of the particular fiscal year; (b) for the purposes of this Part, tax in respect of the employer resource supply is deemed to have become payable on the last day of the particular fiscal year and the person is deemed to have collected that tax on that day; (c) for the purposes of this Part, the tax referred to in paragraph (b) is deemed to be equal to the total of all amounts, each of which is determined for each particular pension plan in the master pension group by the formula A + B where A is the amount determined by the formula C × D × E where C is (i) if the employer resource was consumed by the person during the particular fiscal year in the course of those pension activities, the product obtained when the fair market value of the employer resource at the time the person began consuming it in the particular fiscal year is multiplied by the extent to which that consumption (expressed as a percentage of the total consumption of the employer resource by the person during the particular fiscal year) occurred when the person was both a registrant and a participating employer of any pension plan in the master pension group, or (ii) otherwise, the product obtained when the fair market value of the use of the employer resource during the particular fiscal year as determined on the last day of the particular fiscal year is multiplied by the extent to which the employer resource was used during the particular fiscal year (expressed as a percentage of the total use of the employer resource by the person during the particular fiscal year) in the course of those pension activities when the employer was both a registrant and a participating employer of any pension plan in the master pension group, D is the rate set out in subsection 165(1), and E is the master pension factor in respect of the particular pension plan for the fiscal year of the master pension entity that includes the last day of the particular fiscal year, and B is the total of all amounts, each of which is determined for a participating province by the following formula F × G × H where F is the amount determined for C, G is the provincial factor in respect of the particular pension plan and the participating province for the particular fiscal year, and H is the master pension factor determined for E; and (d) for each pension plan in the master pension group, the specified pension entity of the pension plan is deemed — for the purposes of determining, under section 261.01, an eligible amount of the specified pension entity of the pension plan in respect of the person for the particular fiscal year — to have paid tax on the last day of the particular fiscal year equal to the amount determined by the formula A − B where A is (i) if the specified pension entity is a selected listed financial institution on that day, the amount determined for the pension plan under the description of A in paragraph (c), and (ii) in any other case, the amount of tax determined for the pension plan under paragraph (c), and B is the total of all amounts, each of which is a part of the amount determined for A (i) that is not included in determining the person’s net tax for the reporting period that includes the last day of the particular fiscal year, or (ii) that the person has recovered or is entitled to recover by way of rebate, refund or remission, or otherwise, under this