Income Tax Act — I-3.3 127
he total of all amounts each of which is an amount determined under paragraph 127(13)(d) for the year in respect of the taxpayer; ( compte de dépenses admissibles de recherche et de développement ) super-allowance benefit amount for a particular taxation year in respect of a corporation in respect of a province means the amount determined by the formula (A - B) × C where A is the total of all amounts each of which is an amount that is or may become deductible by the corporation, in computing income or taxable income relevant in calculating an income tax payable by the corporation under a law of the province for any taxation year, in respect of an expenditure on scientific research and experimental development incurred in the particular year, B is the amount by which the amount of the expenditure exceeds the total of all amounts that would be required by subsections (18) to (20) to reduce the corporation’s qualified expenditures otherwise determined under this section if the definitions government assistance and non-government assistance did not apply to assistance provided under that law, and C is (a) where the corporation’s expenditure limit for the particular year is nil, the maximum rate of the province’s income tax that applies for that year to active business income earned in the province by a corporation, and (b) in any other case, the rate of the province’s income tax for that year that would apply to the corporation if (i) it were not associated with any other corporation in the year, (ii) its taxable income for the year were less than $200,000, and (iii) its taxable income for the year were earned in the province in respect of an active business carried on in the province; ( avantage relatif à la superdéduction ) taxable supplier in respect of an amount means (a) a person resident in Canada or a Canadian partnership, or (b) a non-resident person, or a partnership that is not a Canadian partnership, (i) by which the amount was payable, or (ii) by or for whom the amount was receivable in the course of carrying on a business through a permanent establishment (as defined by regulation) in Canada; ( fournisseur imposable ) ultimate parent entity , in respect of a group of entities, means the member of the group that would be the ultimate parent entity , as defined in subsection 233.8(1), of the group if the group were a multinational enterprise group as defined in subsection 233.8(1). ( entité mère ultime ) Transitional application of investment tax credit definition (9.01) For the purpose of applying each of paragraphs (c) to (f), (h) and (i) of the definition investment tax credit in subsection (9) in respect of a taxpayer, the reference to “10” in that paragraph is to be read as a reference to the number that is the lesser of (a) 20, and (b) the number that is the total of 10 and the number of taxation years by which the number of taxation years of the taxpayer that have ended after 1997 exceeds 11. Transitional application of investment tax credit definition (9.02) For the purpose of applying paragraph (g) of the definition investment tax credit in subsection (9) in respect of a taxpayer, the reference to “9” in that paragraph is to be read as a reference to the number that is the lesser of (a) 19, and (b) the number that is the total of 9 and the number of taxation years by which the number of taxation years of the taxpayer that have ended after 1997 exceeds 11. Loss restriction event before end of year (9.1) If a taxpayer is subject to a loss restriction event at any time (in this subsection referred to as “that time”) before the end of a taxation year of the taxpayer, the amount determined for the purposes of paragraph (j) of the definition investment tax credit in subsection (9) with respect to the taxpayer is the amount, if any, by which (a) the amount, if any, by which (i) the total of all amounts added in computing its investment tax credit at the end of the year in respect of a property acquired, or an expendit