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the total of all amounts, each of which is the amount, if any, determined in respect of a partnership by the formula A × B/C – D where A is the total of all amounts each of which is an amount of interest that is deductible by the partnership, and paid by the partnership in, or payable by the partnership in respect of, the taxation year of the taxpayer (depending on the method regularly followed by the taxpayer in computing the taxpayer’s income) on a debt amount included in the taxpayer’s outstanding debts to specified non-residents (as defined in subsection 18(5)), B is the amount determined under paragraph 18(4)(a) in respect of the taxpayer for the year, C is the amount determined under paragraph 18(4)(b) in respect of the taxpayer for the year, and D is the total of all amounts each of which is an amount included under subsection 91(1) in computing the income of the taxpayer for the year or a subsequent taxation year, or of the partnership for a fiscal period, that may reasonably be considered to be in respect of interest described in A;