Income Tax Regulations — 808
e of carrying on business in Canada”, is of the corporation’s taxable income earned in Canada for the year; and (iii) [Repealed, SOR/2009-302, s. 7] (o) the amount, if any, by which (i) the amount (referred to in this paragraph as “provincial tax liability”), if any, by which any income taxes payable for the year by the corporation to the government of a province (to the extent that such taxes were not deductible under Part I of the Act in computing the corporation’s income for the year from a business carried on by it in Canada) exceeds the amount, if any, paid by the corporation before the end of the year on account thereof, exceeds (ii) that proportion of the provincial tax liability that the amount, if any, in respect of the corporation for the year that is the lesser of (A) the amount, if any, by which the total of all amounts each of which is a taxable capital gain of the corporation for the year from a disposition of a taxable Canadian property that was not used or held by it in the year in the course of carrying on business in Canada exceeds the total of all amounts each of which is an allowable capital loss of the corporation for the year from a disposition of such a property, and (B) the amount that would be determined under clause (A) for the year if it were read without reference to the expression “that was not used or held by it in the year in the course of carrying on business in Canada”, is of the corporation’s taxable income earned in Canada for the year. (iii) [Repealed, SOR/2009-302, s. 7] (p) [Repealed, SOR/2009-302, s. 7] (3) For the purposes of paragraph (2)(i), the “allowable liquid assets of the corporation at the end of the year” is an amount equal to the lesser of (a) the aggregate of (i) the amount of Canadian currency owned by the corporation at the end of that year, (ii) the balance standing to the credit of the corporation at the end of that year as or on account of amounts deposited with a branch or other office in Canada of (A) a bank, (B) a corporation licenced or otherwise authorized under the laws of Canada or a province to carry on in Canada the business of offering to the public its services as trustee, or (C) a credit union, and (iii) an amount equal to the aggregate of the cost amount to the corporation at the end of that year of each bond, debenture, bill, note, mortgage or similar obligation that was not described in the corporation’s inventory in respect of a business carried on by it in Canada (other than a debt referred to in paragraph (2)(e) or (g) or a debt the amount of which was deducted under paragraph 20(1)(p) of the Act in computing the corporation’s income for the year), that was issued by a person resident in Canada with whom the corporation was dealing at arm’s length and that matures within one year after the date on which it was acquired by the corporation, to the extent that such amounts are attributable to the profits of the corporation from carrying on a business in Canada, or are used or held by the corporation in the year in the course of carrying on a business in Canada; and (b) an amount equal to 4/3 of the quotient obtained by dividing (i) the aggregate of all amounts that would otherwise be determined under subparagraphs (a)(i), (ii) and (iii) if the references therein to “at the end of that year” were read as references to “at the end of each month in that year”, by (ii) the number of months in that year. (4) For the purposes of subsection (1), where, at the end of a taxation year, a corporation is a member of a partnership that was carrying on business in Canada at any time in that year, the corporation’s qualified investment in property in Canada at the end of the year is an amount equal to the aggregate of (a) the amount, if any, that would be determined under subsection (2) if the corporation were not, at the end of the year, a member of a partnership that was carrying on business in Canada at any time in the year; and (b) an amount equal to the portion of th