92.32. For the purposes of section 1037, where the second paragraph of section 92.31 provides for the inclusion of a particular amount described in subparagraph a of that second paragraph in computing the income of an entity for a taxation year, the entity is deemed to have an amount of unpaid tax immediately after the entity’s balance-due day for the year computed as if(a) the entity had been resident in Canada throughout the year;
(b) the entity’s tax payable for the year were equal to the tax payable by the entity on its taxable income for the year;
(c) the particular amount were the entity’s only taxable income for the year;
(d) the entity had claimed no deductions under Book V for the year;
(e) the entity had not paid any amounts on account of its tax payable for the year; and
(f) the tax payable to which paragraph b applies had been an amount of unpaid tax throughout the period that begins immediately after the end of the taxation year for which the particular amount was deducted and that ends on the entity’s balance-due day for the year.