Income Tax Act — I-3.3 127
ection 127(8.1), a taxpayer’s expenditure base in respect of a partnership at the end of a taxation year of the partnership is the lesser of (a) the amount, if any, by which the total of (i) the taxpayer’s at-risk amount in respect of the partnership at the time the taxpayer last became a limited partner of the partnership, (ii) all amounts described in subparagraph 53(1)(e)(iv) contributed by the taxpayer after the time the taxpayer last became a limited partner of the partnership and before the end of the year that may reasonably be considered to have increased the taxpayer’s at-risk amount in respect of the partnership at the end of the taxation year in which the contribution was made, and (iii) the amount, if any, by which (A) the total of all amounts each of which is the taxpayer’s share of any income of the partnership as determined under paragraph 96(1)(f) for the year, or a preceding year ending after the time the taxpayer last became a limited partner of the partnership, exceeds (B) the total of all amounts each of which is the taxpayer’s share of any loss of the partnership as determined under paragraph 96(1)(g) for one of those years exceeds the total of (iv) all amounts received by the taxpayer after the time the taxpayer last became a limited partner of the partnership and before the end of the year as, on account or in lieu of payment of, or in satisfaction of, a distribution of the taxpayer’s share of partnership profits or partnership capital, and (v) the total of all amounts each of which is the amount of an expenditure of the partnership referred to in paragraph 127(8.1)(a) in respect of the taxpayer for a preceding year, and (b) that proportion of the lesser of (i) the total of all amounts each of which is, if the partnership were a person and its fiscal period were its taxation year, (A) an amount a specified percentage of which would be determined in respect of the partnership under paragraph (a), (b) or (e.1) of the definition investment tax credit in subsection 127(9) for the year, (A.1) an amount that would be the apprenticeship expenditure of the partnership if the reference to “$2,000” in paragraph (a) of the definition apprenticeship expenditure in subsection (9) were read as a reference to “$20,000” and paragraph (b) of that definition were read without reference to “10% of”, or (A.2) [Repealed, 2017, c. 20, s. 23] (B) the amount that would be the SR&ED qualified expenditure pool of the partnership at the end of the year, and (ii) the total of all amounts each of which is the amount determined under paragraph 127(8.2)(a) in respect of each of the limited partners of the partnership at the end of the year that (iii) the amount determined in respect of the taxpayer under paragraph 127(8.2)(a) for the year is of (iv) the amount determined under subparagraph 127(8.2)(b)(ii). Investment tax credit — allocation of unallocated partnership ITCs (8.3) For the purpose of subsection (8), and subject to subsection (8.4), if a taxpayer is a member of a partnership (other than a specified member) throughout a fiscal period of the partnership, there shall be added to the amount that can reasonably be considered to be that member’s share of the amount determined under subsection (8) the amount, if any, that is such portion of the amount determined under subsection (8.31) in respect of that fiscal period as is reasonable in the circumstances (having regard to the investment in the partnership, including debt obligations of the partnership, of each of those members of the partnership who was a member of the partnership throughout the fiscal period of the partnership and who was not a specified member of the partnership during the fiscal period of the partnership). Amount of unallocated partnership ITC (8.31) For the purpose of subsection (8.3), the amount determined under this subsection in respect of a fiscal period of a partnership is the amount, if any, by which (a) the total of all amounts each of which is an amo