Income Tax Act — I-3.3 34.2
e or taxable capital gain of the partnership for the eligible fiscal period, other than any amount (i) for which a deduction is available under section 112 or 113, or (ii) that would be included in computing the income of the corporation for the year if there were no multi-tier alignment, B is the total of all amounts each of which is the corporation’s share of a loss or allowable capital loss — to the extent that the total of all allowable capital losses does not exceed the total of all taxable capital gains included in the description of A — of a partnership for the eligible fiscal period, and C is, where an outlay or expense of the partnership is deemed by subsection 66(18) to be made or incurred by the corporation at the end of the eligible fiscal period, the total of all amounts each of which is an amount that would be deductible by the corporation for the taxation year under any of sections 66.1, 66.2, 66.21 and 66.4 determined as if each such outlay or expense were the only amount relevant in determining the amount deductible. ( revenu d’alignement admissible ) multi-tier alignment , in respect of a partnership, means the alignment under subsection 249.1(9) or (11) of the fiscal period of the partnership and the fiscal period of one or more other partnerships.  ( alignement pour paliers multiples ) qualified resource expense , of a corporation for a taxation year in respect of a fiscal period of a partnership that begins in the year and ends after the year, means an expense incurred by the partnership in the portion of the fiscal period that is in the year and that is described in any of the following definitions: (a) Canadian exploration expense in subsection 66.1(6); (b) Canadian development expense in subsection 66.2(5); (c) foreign resource expense in subsection 66.21(1); and (d) Canadian oil and gas property expense in subsection 66.4(5). ( dépense admissible relative à des ressources ) qualifying transitional income , of a corporation that is a member of a partnership on March 22, 2011, means the amount that is the total of the following amounts, computed in accordance with subsection (15), (a) the corporation’s eligible alignment income in respect of the partnership, and (b) the corporation’s adjusted stub period accrual in respect of the partnership for (i) if there is a multi-tier alignment in respect of the partnership, the corporation’s taxation year during which ends the fiscal period of the partnership that is aligned with the fiscal period of one or more other partnerships under the multi-tier alignment, or (ii) in any other case, the corporation’s first taxation year that ends after March 22, 2011. ( revenu admissible à l’allègement ) significant interest , of a corporation in a partnership at any time, means a membership interest of the corporation in the partnership if the corporation, or the corporation together with one or more persons or partnerships related to or affiliated with the corporation, is entitled at that time to more than 10% of (a) the income or loss of the partnership; or (b) the assets (net of liabilities) of the partnership if it were to cease to exist. ( participation importante ) single-tier alignment , in respect of a partnership, means the ending of a fiscal period of the partnership under subsection 249.1(8). ( alignement pour palier unique ) specified percentage , of a corporation for a particular taxation year in respect of a partnership, means (a) if the first taxation year for which the corporation has qualifying transitional income ends in 2011 and the particular year ends in (i) 2011, 100%, (ii) 2012, 85%, (iii) 2013, 65%, (iv) 2014, 45%, (v) 2015, 25%, and (vi) 2016, 0%; (b) if the first taxation year for which the corporation has qualifying transitional income ends in 2012 and the particular year ends in (i) 2012, 100%, (ii) 2013, 85%, (iii) 2014, 65%, (iv) 2015, 45%, (v) 2016, 25%, and (vi) 2017, 0%; and (c) if the first taxation year for which the corporation has qualif