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Versions of s. 212(3.3)

I-3.3 — Income Tax Act · 3 versions · View current text

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

  1. 2017-12-14 to present available View Source
    Subsection (3.4) applies in respect of a particular relevant funder if the amount determined by the following formula is greater than nil: A – B where A is the total of all amounts each of which is the amount owing by the particular relevant funder, or is the fair market value of a property in respect of which the particular relevant funder has a specified right, under a relevant funding arrangement; and B is the total of all amounts each of which is the amount owed to the particular relevant funder, or is the fair market value of a property in respect of which the particular relevant funder has granted a specified right, under a relevant funding arrangement.
    Full text

    Subsection (3.4) applies in respect of a particular relevant funder if the amount determined by the following formula is greater than nil: A – B where A is the total of all amounts each of which is the amount owing by the particular relevant funder, or is the fair market value of a property in respect of which the particular relevant funder has a specified right, under a relevant funding arrangement; and B is the total of all amounts each of which is the amount owed to the particular relevant funder, or is the fair market value of a property in respect of which the particular relevant funder has granted a specified right, under a relevant funding arrangement.

  2. 2017-01-01 to 2017-12-14 View Source
    IfSubsection subsection (3.2)(3.4) applies at any time to deem a taxpayer to pay interest at that time to more than one non-resident person referred to in subparagraph (3.1)(c)(i) or (ii) in respect of a particular debtrelevant orfunder otherif obligationthe andamount determined by the following formula is greater than nil: A – B where A is the total of all amounts determined (without reference to this subsection) for B in subsection (3.2) in respect of the particular debt or other obligation exceeds the average of all amounts each of which is the amount ofowing by the particular debtrelevant funder, or otheris obligationthe outstandingfair atmarket value of a time in the relevant period, then the taxpayer may reduce the amount determined for Bproperty in respect of one or more ofwhich the non-residentparticular personsrelevant byfunder onehas ora morespecified amountsright, designatedunder bya therelevant taxpayer,funding asarrangement; and B is reasonable in the circumstances, the total of which designatedall amounts shalleach notof bewhich greateris thanthe thatamount excess.owed to the particular relevant funder, or is the fair market value of a property in respect of which the particular relevant funder has granted a specified right, under a relevant funding arrangement.
    Full text

    Subsection (3.4) applies in respect of a particular relevant funder if the amount determined by the following formula is greater than nil: A – B where A is the total of all amounts each of which is the amount owing by the particular relevant funder, or is the fair market value of a property in respect of which the particular relevant funder has a specified right, under a relevant funding arrangement; and B is the total of all amounts each of which is the amount owed to the particular relevant funder, or is the fair market value of a property in respect of which the particular relevant funder has granted a specified right, under a relevant funding arrangement.

  3. 2014-12-16 to 2017-01-01 View Source

    If subsection (3.2) applies at any time to deem a taxpayer to pay interest at that time to more than one non-resident person referred to in subparagraph (3.1)(c)(i) or (ii) in respect of a particular debt or other obligation and the total of all amounts determined (without reference to this subsection) for B in subsection (3.2) in respect of the particular debt or other obligation exceeds the average of all amounts each of which is the amount of the particular debt or other obligation outstanding at a time in the relevant period, then the taxpayer may reduce the amount determined for B in respect of one or more of the non-resident persons by one or more amounts designated by the taxpayer, as is reasonable in the circumstances, the total of which designated amounts shall not be greater than that excess.