Versions of s. 15(2.19)(b)

I-3.3 — Income Tax Act · 2 versions · View current text

Historical text comes from the Justice Laws point-in-time corpus and is unofficial — not the official version.

2018-12-13 to present available View Source

the total amount of the deemed repayments referred to in paragraph (a) is to be determined by the following formula: A – B – C where A is the total of all amounts, each of which is the amount of a loan deemed by subsection (2.17) to have been received, at any time before the particular time, by the intended borrower from the particular ultimate funder in respect of the shareholder debt, B is the total of all amounts deemed by this subsection to have been repaid, at any time before the particular time, by the intended borrower in respect of any loans referred to in the description of A, and C is the amount determined by the formula D × E/F where D is the lesser of the amount outstanding as or on account of the shareholder debt, immediately after the particular time, and the total of all amounts, each of which is, immediately after the particular time, an amount outstanding as or on account of a debt or other obligation that is owed by a funder (other than an ultimate funder) to an ultimate funder under a funding arrangement in respect of the shareholder debt, or the fair market value of a particular property in respect of which an ultimate funder has granted a specified right to a funder (other than an ultimate funder) under a funding arrangement in respect of the shareholder debt, E is the total of all amounts, each of which is, immediately after the particular time an amount outstanding as or on account of a debt or other obligation that is owed by a funder (other than an ultimate funder) to the particular ultimate funder under a funding arrangement in respect of the shareholder debt, or the fair market value of a particular property in respect of which the particular ultimate funder has granted a specified right to a funder (other than an ultimate funder) under a funding arrangement in respect of the shareholder debt, and F is the amount determined under subparagraph (ii) in the description of D.

Full text

the total amount of the deemed repayments referred to in paragraph (a) is to be determined by the following formula: A – B – C where A is the total of all amounts, each of which is the amount of a loan deemed by subsection (2.17) to have been received, at any time before the particular time, by the intended borrower from the particular ultimate funder in respect of the shareholder debt, B is the total of all amounts deemed by this subsection to have been repaid, at any time before the particular time, by the intended borrower in respect of any loans referred to in the description of A, and C is the amount determined by the formula D × E/F where D is the lesser of the amount outstanding as or on account of the shareholder debt, immediately after the particular time, and the total of all amounts, each of which is, immediately after the particular time, an amount outstanding as or on account of a debt or other obligation that is owed by a funder (other than an ultimate funder) to an ultimate funder under a funding arrangement in respect of the shareholder debt, or the fair market value of a particular property in respect of which an ultimate funder has granted a specified right to a funder (other than an ultimate funder) under a funding arrangement in respect of the shareholder debt, E is the total of all amounts, each of which is, immediately after the particular time an amount outstanding as or on account of a debt or other obligation that is owed by a funder (other than an ultimate funder) to the particular ultimate funder under a funding arrangement in respect of the shareholder debt, or the fair market value of a particular property in respect of which the particular ultimate funder has granted a specified right to a funder (other than an ultimate funder) under a funding arrangement in respect of the shareholder debt, and F is the amount determined under subparagraph (ii) in the description of D.
2016-12-15 to 2018-12-13 View Source

the total amount of the deemed repayments referred to in paragraph (a) is to be determined by the following formula: A – B – C where A is the total of all amounts, each of which is the amount of a loan deemed by subsection (2.17) to have been received, at any time before the particular time, by the intended borrower from the particular ultimate funder in respect of the shareholder debt, B is the total of all amounts deemed by this subsection to have been repaid, at any time before the particular time, by the intended borrower in respect of any loans referred to in the description of A, and C is the amount determined by the formula D × E/F where D is the lesser of the amount outstanding as or on account of the shareholder debt, immediately after the particular time, and the total of all amounts, each of which is, immediately after the particular time, an amount outstanding as or on account of a debt or other obligation that is owed by a funder (other than an ultimate funder) to an ultimate funder under a funding arrangement in respect of the shareholder debt, or the fair market value of a particular property in respect of which an ultimate funder has granted a specified right to a funder (other than an ultimate funder) under a funding arrangement in respect of the shareholder debt, E is the total of all amounts, each of which is, immediately after the particular time an amount outstanding as or on account of a debt or other obligation that is owed by a funder (other than an ultimate funder) to the particular ultimate funder under a funding arrangement in respect of the shareholder debt, or the fair market value of a particular property in respect of which the particular ultimate funder has granted a specified right to a funder (other than an ultimate funder) under a funding arrangement in respect of the shareholder debt, and F is the amount determined under subparagraph (ii) in the description of D.