Income Tax Act — I-3.3 18
 been in existence throughout the particular period, and (d) to have had, throughout the particular period, taxation years ending on the day of the year on which its first taxation year ended. Idem (9.7) Where the amount paid by a borrower at any particular time, in satisfaction of the obligation to pay a particular amount of interest on a debt obligation in respect of a subsequent period or part thereof, exceeds the particular amount of that interest, discounted (a) for the particular period beginning at the particular time and ending at the end of the subsequent period or part thereof, and (b) at the rate or rates of interest applying under the debt obligation during the particular period (or, where the rate of interest of any part of the particular period is not fixed at the particular time, at the prescribed rate of interest in effect at the particular time), that excess shall (c) for the purposes of applying subsections 18(9.2) to 18(9.6) and 18(9.8), be deemed to be neither an amount of interest payable on the debt obligation nor an amount paid in satisfaction of the obligation to pay interest on the debt obligation, and (d) be deemed to be a payment described in paragraph 18(9.1)(d) in respect of the debt obligation. Idem (9.8) Nothing in any of subsections 18(9.2) to 18(9.7) shall be construed as providing that (a) the total of all amounts each of which is the amount of interest payable on a debt obligation by an individual (other than a trust), or deemed by subsection 18(9.2) to be payable on the debt obligation by a corporation, partnership or trust, in respect of a taxation year ending after 1991 and before any particular time, may exceed (b) the total of all amounts each of which is the amount of interest payable on the debt obligation (determined without reference to subsection 18(9.2)) by a person or partnership in respect of a taxation year ending after 1991 and before that particular time. Employee benefit plan (10) Paragraph 18(1)(o) does not apply in respect of a contribution to an employee benefit plan (a) to the extent that the contribution (i) is made in respect of services performed by an employee who is not resident in Canada and is regularly employed in a country other than Canada, and (ii) cannot reasonably be regarded as having been made in respect of services performed or to be performed during a period when the employee is resident in Canada; (b) the custodian of which is non-resident, to the extent that the contribution (i) is in respect of an employee who is non-resident at the time the contribution is made, and (ii) cannot reasonably be regarded as having been made in respect of services performed or to be performed during a period when the employee is resident in Canada; or (c) the custodian of which is non-resident, to the extent that the contribution can reasonably be regarded as having been made in respect of services performed by an employee in a particular calendar month where (i) the employee was resident in Canada throughout no more than 60 of the 72 calendar months ending with the particular month, and (ii) the employee became a member of the plan before the end of the month following the month in which the employee became resident in Canada, and for the purpose of this paragraph, where benefits provided to an employee under a particular employee benefit plan are replaced by benefits provided under another employee benefit plan, the other plan shall be deemed, in respect of the employee, to be the same plan as the particular plan. Limitation (11) Notwithstanding any other provision of this Act, in computing the income of a taxpayer for a taxation year, no amount is deductible under paragraph 20(1)(c), 20(1)(d), 20(1)(e), 20(1)(e.1) or 20(1)(f) in respect of borrowed money (or other property acquired by the taxpayer) in respect of any period after which the money (or other property) is used by the taxpayer for the purpose of (a) making a payment after November 12, 1981 as consideration fo