851.22.11R3. A method for allocating to taxation years in respect of the residual portion of a taxpayer’s gain or loss from the disposition of a specified debt obligation, is a method referred to in paragraph a of section 851.22.11R2 if the amount allocated to each taxation year is determined by the formula
A × B/C.
In the formula in the first paragraph,(a) A is the residual portion of the taxpayer’s gain or loss;
(b) B is the number of days in the taxation year that are in the period referred to in subparagraph c; and
(c) C is the number of days in the period that is,i. where the obligation is part of a group of obligations to which section 851.22.11R4 applies, the period referred to in that section, and
ii. where subparagraph i does not apply, the period that begins on the day on which the taxpayer disposed of the obligation and ends on the earlier of the amortization date for the obligation and the day that is 20 years after the day on which the taxpayer disposed of the obligation.