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If this subsection applies in respect of a foreign affiliate (referred to in this subsection as the “actual affiliate”), other than a controlled foreign affiliate, of a taxpayer for a taxation year of the actual affiliate, the following rules apply for the purpose of determining the amounts, if any, to be included under subsection 91(1), and to be deducted under subsection 91(4), by the taxpayer in respect of the year and for the purpose of applying section 233.4 in respect of the year: