Income Tax Act — I-3.3 89
for a taxation year of the corporation that ended after 2003 and before 2006, determined before taking into consideration the specified future tax consequences for that taxation year, and (c) all amounts each of which was deductible under subsection 112(1) in computing the corporation’s taxable income for a taxation year of the corporation (in this paragraph referred to as the “particular corporation”) that ended after 2000 and before 2006, and is in respect of a dividend received from a corporation (in this paragraph referred to as the “payer corporation”) that was, at the time it paid the dividend, connected (within the meaning assigned by subsection 186(4)) with the particular corporation, to the extent that it is reasonable to consider, having regard to all the circumstances (including but not limited to other shareholders having received dividends from the payer corporation), that the dividend was attributable to an amount that is, or if this subsection applied to the payer corporation would be, described in this paragraph or in paragraph (a) or (b) in respect of the payer corporation; and B is the total of all amounts each of which is a taxable dividend paid by the corporation in those taxation years. LRIP addition — ceasing to be CCPC (8) If, in a particular taxation year, a corporation is neither a Canadian-controlled private corporation nor a deposit insurance corporation but was, in its preceding taxation year, a Canadian-controlled private corporation or a deposit insurance corporation, there shall be included in computing the corporation’s low rate income pool at any time in the particular taxation year the amount determined by the formula A + B + C - D - E - F - G - H where A is the total of all amounts each of which is the cost amount to the corporation of a property immediately before the end of its preceding taxation year; B is the amount of any money of the corporation on hand immediately before the end of its preceding taxation year; C is the amount, if any, by which (a) the total of all amounts that, if the corporation had had unlimited income for its preceding taxation year from each business carried on, and from each property held, by it in that preceding taxation year and had realized an unlimited amount of capital gains for that preceding taxation year, would have been deductible under subsection 111(1) in computing its taxable income for that preceding taxation year exceeds (b) the total of all amounts deducted under subsection 111(1) in computing the corporation’s taxable income for its preceding taxation year; D is the total of all amounts each of which is the amount of any debt owing by the corporation, or of any other obligation of the corporation to pay any amount, that was outstanding immediately before the end of its preceding taxation year; E is the paid up capital, immediately before the end of its preceding taxation year, of all of the issued and outstanding shares of the capital stock of the corporation; F is the total of all amounts each of which is a reserve deducted in computing the corporation’s income for its preceding taxation year; G is (a) if the corporation is not a private corporation in the particular taxation year, the corporation’s capital dividend account, if any, immediately before the end of its preceding taxation year, and (b) in any other case, nil; and H is the positive or negative amount determined by the formula I - J where I is the corporation’s general rate income pool at the end of its preceding taxation year, and J is the amount, if any, by which (a) the total of all amounts each of which is an eligible dividend paid by the corporation in its preceding taxation year exceeds (b) the total of all amounts each of which is an excessive eligible dividend designation made by the corporation in its preceding taxation year. LRIP addition — amalgamation (9) If a corporation that is resident in Canada and that is neither a Canadian-controlled private corporation nor a deposit i