Income Tax Act — I-3.3 261
o be determined (A) if the particular taxation year is the taxpayer’s first functional currency year, without reference to this section, and (B) in any other case, as if the taxes payable by the taxpayer for the taxpayer’s functional currency year (referred to in this paragraph as the “first base year”) immediately preceding the particular taxation year were the total of (I) the total of the taxpayer’s payment obligations under paragraph 157(1)(a) or (1.1)(a), as determined with reference to this subparagraph or subparagraph (i) or (iii), as the case may be, in respect of the first base year, and (II) the amount, if any, of the remainder of the taxes payable by the taxpayer under paragraph 157(1)(b) or (1.1)(b), as determined under paragraph (b), in respect of the first base year, and (iii) the taxpayer’s second instalment base (within the meaning assigned by subsection 157(4)) for the particular taxation year is to be determined (A) if the particular taxation year is the taxpayer’s first functional currency year or its taxation year that immediately follows its first functional currency year, without reference to this section, and (B) in any other case, as if the taxes payable by the taxpayer for the taxpayer’s functional currency year (referred to in this subparagraph as the “second base year”) immediately preceding the first base year were the total of (I) the total of the taxpayer’s payment obligations under paragraph 157(1)(a) or (1.1)(a), as determined with reference to this subparagraph or subparagraph (i) or (ii), as the case may be, in respect of the second base year, and (II) the amount, if any, of the remainder of the taxes payable by the taxpayer under paragraph 157(1)(b) or (1.1)(b), as determined under paragraph (b), in respect of the second base year; (b) the remainder of the taxes payable by the taxpayer under paragraph 157(1)(b) or (1.1)(b) for the particular taxation year is the amount, if any, determined by (i) computing the amount, if any, by which (A) the total of the taxes payable by the taxpayer under Parts I, VI, VI.1 and XIII.1 for the particular taxation year, as determined in the taxpayer’s elected functional currency exceeds (B) the total of all amounts each of which is the amount determined by converting the amount of a payment obligation — determined by paragraph 157(1)(a) or (1.1)(a), as the case may be, with reference to subparagraph (a)(i), (ii) or (iii), as the case may be — of the taxpayer in respect of the particular taxation year to the taxpayer’s elected functional currency using the relevant spot rate for the day on which the payment obligation was due, and (ii) converting the amount, if any, determined by subparagraph (i) to Canadian currency using the relevant spot rate for the taxpayer’s balance-due day for the partic-ular taxation year; (c) for the purposes of determining any amount (other than tax) that is payable by the taxpayer under Part I, VI, VI.1 or XIII.1 for the particular taxation year, the taxpayer’s tax payable under the Part for the particular taxation year is deemed to be equal to the total of (i) the total of the taxpayer’s payment obligations under paragraph 157(1)(a) or (1.1)(a), in respect of the Part, as determined with reference to subparagraph (a)(i), (ii) or (iii), as the case may be, in respect of the particular taxation year, and (ii) the amount, if any, of the remainder of the taxes payable by the taxpayer under paragraph 157(1)(b) or (1.1)(b), in respect of the Part, as determined under paragraph (b), in respect of the particular taxation year; (d) amounts of tax that are payable under this Act (except under Parts I, VI, VI.1 and XIII.1) by the taxpayer for the particular taxation year are to be determined by converting those amounts, as determined in the taxpayer’s elected functional currency, to Canadian currency using the relevant spot rate for the day on which those amounts are due; (e) if a particular amount that is determined in the taxpayer’s elected f