Versions of s. 18.4(1), definition “foreign ordinary income”

foreign ordinary income, of an entity for a foreign taxation year in respect of a payment, means an amount that is determined by the formula A − B − C − D − E − F where A is an amount (referred to in this definition as the “relevant amount”) that is included in respect of the payment in computing relevant foreign income or profits of the entity for the year (other than income or profits in respect of which the entity is subject to a tax substantially similar to tax under Part XIII, or a tax under a controlled foreign company tax regime or a specified minimum tax regime) because the entity is a recipient of the payment or has a direct or indirect equity interest in a recipient of the payment; B is if the relevant amount is included in computing relevant foreign income or profits in respect of which the entity is subject to an income or profits tax that is charged at a nil rate, the relevant amount, or in any other case, nil; C is any portion of the relevant amount that is included in computing relevant foreign income or profits of the entity for the year because of any foreign hybrid mismatch rule (other than any rule that is substantially similar in effect to subsection 113(5)); D is any portion of the relevant amount that can reasonably be considered to be excluded, reduced, offset or otherwise effectively sheltered from income or profits tax by reason of any exemption, exclusion, deduction, credit (other than a credit for tax payable under Part XIII) or other form of relief that applies specifically in respect of all or a portion of the relevant amount and not in computing the entity’s relevant foreign income or profits in general, or arises in respect of the payment; E is the amount determined by the formula(A − C − D) × G ÷ H where G is the total of all amounts, each of which is an amount that meets the following conditions: is repaid or repayable in respect of income or profits tax paid or payable by the entity to the government of a country other than Canada in respect of the relevant foreign income or profits for the year, and is not repaid or repayable because a loss is used to reduce or offset the relevant foreign income or profits for the year, or is paid or payable in respect of a credit that can reasonably be considered to reduce or offset, directly or indirectly, the income or profits tax referred to in clause (i)(A), and H is the total amount of the income or profits tax referred to in clause (i)(A) of the description of G; and F is the amount determined by the formula(A − C − D − E) × (1 − I ÷ J) where I is the rate at which the income or profits tax referred to in clause (i)(A) in the description of G is charged in respect of the relevant amount, and J is the highest rate at which an income or profits tax imposed by the government of the country is charged in respect of an amount of income in respect of a financial instrument. (revenu ordinaire étranger)