Income Tax Act — I-3.3 125.5
Canada by the individual in respect of the accredited production, or (iv) a partnership, to the extent that the amount paid (A) is attributable to services personally rendered in respect of the accredited production by an individual who is resident in Canada and who is a member of the partnership, or (B) is attributable to and does not exceed the salary or wages paid by the partnership to its employees at a time when they were resident in Canada for personally rendering services in Canada in respect of the accredited production, and (c) where (i) the corporation is a subsidiary wholly-owned corporation of another corporation that is a taxable Canadian corporation (in this section referred to as the “parent”), and (ii) the corporation and the parent have filed with the Minister an agreement that this paragraph apply in respect of the production, the reimbursement made by the corporation in the year, or within 60 days after the end of the year, of an expenditure that was incurred by the parent in a particular taxation year of the parent in respect of the production and that would be included in the Canadian labour expenditure of the corporation in respect of the production for the particular taxation year because of paragraph (a) or (b) if (iii) the corporation had had such a particular taxation year, and (iv) the expenditure were incurred by the corporation for the same purpose as it was incurred by the parent and were paid at the same time and to the same person or partnership as it was paid by the parent. ( dépense de main-d’oeuvre au Canada ) eligible production corporation , in respect of an accredited production for a taxation year, means a corporation, the activities of which in the year in Canada are primarily the carrying on through a permanent establishment (as defined by regulation) in Canada of a film or video production business or a film or video production services business and that (a) owns the copyright in the accredited production throughout the period during which the production is produced in Canada, or (b) has contracted directly with the owner of the copyright in the accredited production to provide production services in respect of the production, where the owner of the copyright is not an eligible production corporation in respect of the production,except a corporation that is, at any time in the year, (c) a person all or part of whose taxable income is exempt from tax under this Part, (d) controlled directly or indirectly in any manner whatever by one or more persons all or part of whose taxable income is exempt from tax under this Part, or (e) prescribed to be a labour-sponsored venture capital corporation for the purpose of section 127.4. ( société de production admissible ) qualified Canadian labour expenditure of an eligible production corporation for a taxation year in respect of an accredited production means the amount, if any, by which (a) the total of all amounts each of which is the corporation’s Canadian labour expenditure for the year or a preceding taxation year exceeds the aggregate of (b) the total of all amounts, each of which is an amount of assistance that can reasonably be considered to be in respect of amounts included in the total determined under paragraph (a) in respect of the corporation for the year that, at the time of filing its return of income for the year, the corporation or any other person or partnership has received, is entitled to receive or can reasonably be expected to receive, that has not been repaid before that time pursuant to a legal obligation to do so (and that does not otherwise reduce that expenditure), (c) the total of all amounts, each of which is the qualified Canadian labour expenditure of the corporation in respect of the accredited production for a preceding taxation year before the end of which the principal filming or taping of the production began, and (d) where the corporation is a parent, the total of all amounts each of which is included in the tot