Full text
If an amount is deemed by subsection 96(1.11) to be a taxable dividend received by a person in a taxation year of the person in respect of a partnership, and it is reasonable to consider that all or part of the amount (in this subsection referred to as the “foreign-source portion”) is attributable to income of the partnership from a source in a country other than Canada, the person is deemed for the purposes of this section to have an amount of income from that source for that taxation year equal to the amount determined by the formula A × B/C where A is the total amount included under subsection 82(1) in computing the income of the person in respect of the taxable dividend for that taxation year; B is the foreign-source portion; and C is the amount of the taxable dividend deemed to be received by the person.