418.1.9. In this division, the global foreign resource limit of a taxpayer for a taxation year means the amount that is the lesser of (a) the amount by which the amount determined under paragraph b of section 374 in respect of the taxpayer for the year exceeds the total of i. the aggregate of all amounts each of which is the maximum amount that the taxpayer would be permitted to deduct, in relation to a country, under section 418.1.10 in computing the taxpayer’s income for the year if, in its application to the year, that section were read without reference to paragraph b thereof, and
ii. the amount deducted under section 371 in computing the taxpayer’s income for the year; and
(b) the amount by which 30% of the aggregate of all amounts each of which is, at the end of the year, the taxpayer’s adjusted cumulative foreign resource expense in relation to a country exceeds the aggregate described in subparagraph i of paragraph a.