Income Tax Application Rules — I-3.31 (a)
tax equity of a partnership at any particular time means the amount, if any, by which the total of all amounts each of which is (a) the amount of any money of the partnership on hand at the beginning of its first fiscal period ending after 1971, (b) the cost amount to the partnership, at the beginning of that fiscal period, of any partnership property other than capital property or eligible capital property, (c) an amount in respect of any property (other than depreciable property) that was, at the beginning of that fiscal period, capital property of the partnership, equal to, (i) where the property was disposed of before 1972, the proceeds of disposition thereof, (ii) where the property was disposed of after 1971 and before the particular time, the amount determined under this section to be its cost to the partnership for the purposes of computing its adjusted cost base to the partnership immediately before it was disposed of, and (iii) in any other case, the amount determined under this section to be its cost to the partnership for the purposes of computing its adjusted cost base to the partnership immediately before the particular time, (d) an amount in respect of any prescribed class of depreciable property of the partnership, equal to the amount, if any, by which the total of the undepreciated capital cost to the partnership of property of that class as of January 1, 1972 exceeds the capital cost to the partnership of property of that class acquired by it after the beginning of that fiscal period and before 1972, (e) an amount in respect of any other depreciable property of the partnership at the beginning of that fiscal period, equal to the amount by which (i) the actual cost of the property to the partnership, or the amount at which the partnership was deemed to have acquired the property under subsection 20(6) of the former Act as it read in its application to the 1971 taxation year, as the case may be, exceeds (ii) the total of all amounts in respect of the cost of the property that were allowed under paragraph 11(1)(a) of the former Act as it read in computing the income from the partnership of the members thereof for taxation years ending before 1972, (f) an amount in respect of any property that was, at the beginning of that fiscal period, partnership property that was depreciable property, equal to (i) where the property was disposed of before 1972, the proceeds of disposition thereof minus the amount, if any, by which the lesser of (A) the proceeds of disposition thereof, and (B) the capital cost of the property, exceeds (C) in respect of depreciable property of a prescribed class, the undepreciable capital cost of all of the property of that class at the time of the disposition, or (D) in respect of any other depreciable property, the amount that would be determined under paragraph (e) if the words “at the beginning of that fiscal period” were read as “at the time of the disposition”, (ii) where the property was disposed of after 1971 and before the particular time, the amount, if any, by which the lesser of (A) the proceeds of disposition thereof, and (B) the fair market value of the property on valuation day, exceeds the capital cost to the partnership of the property, and (iii) in any other case, the amount, if any, by which (A) the lesser of the fair market value of the property on valuation day and its fair market value at the particular time exceeds (B) the capital cost to the partnership of the property, or (g) an amount in respect of any business carried on by the partnership in its 1971 fiscal period and thereafter without interruption until the particular time, equal to the amount, if any, by which (i) 2 times the eligible capital amounts (within the meaning assigned by section 14 of the amended Act) in respect of the business (computed without reference to section 21 of this Act) that would have become payable to the partnership would exceed (ii) the amount that would be deemed by subsection 21(1) to