I-3 - Taxation Act

Section 671.1 Disposition versions

2006-03-01

671.1. A taxpayer who is a beneficiary under a trust is deemed, for the purposes of this section and sections 146.1 and 772.2 to 772.13, to have paid to the government of a foreign country or political subdivision of a foreign country, as business-income tax or non-business-income tax, as the case may be, for a particular taxation year in respect of a particular source situated in that country, the amount determined by the formula

A × B / C.

For the purposes of the formula in the first paragraph,

(a)  A is the amount that, but for section 671.3, would be the business-income tax or non-business-income tax, as the case may be, paid by the trust to the government of the foreign country or political subdivision of the foreign country in respect of the particular source for a taxation year, referred to in this paragraph as “that year”, of the trust that ends in the particular year;

(b)  B is the amount deemed, because of a designation made in accordance with section 671 for that year by the trust, to be the taxpayer’s income from the particular source; and

(c)  C is the trust’s income for that year from the particular source.

1995, c. 63, s. 48.