I-3 - Taxation Act

Section 772.5.1.2 Disposition versions

2017-02-08

772.5.1.2. For the purposes of section 772.5.1.1, a taxpayer is not to be considered to have a lesser direct or indirect share of a partnership’s income under the relevant foreign tax law than for the purposes of this Act solely because of one or more of the following:

(a)  a difference between the relevant foreign tax law and this Act in the manner of

i.  computing the partnership’s income, or

ii.  allocating the partnership’s income because of the admission to, or withdrawal from, the partnership of any of its members;

(b)  the fact that the partnership is considered as a corporation under the relevant foreign tax law; or

(c)  the fact that the taxpayer is not considered as a corporation under the relevant foreign tax law.

2017, c. 1, s. 217.