Income Tax Regulations

405 (1) Notwithstanding subsections 402(3) and (4), the amount of taxable income that shall be deemed to have been earned in a taxation year by a trust and loan corporation, trust corporation or loan corporation in a province in which it had a permanent establishment is that proportion of its taxable income for the year that the gross revenue for the year of its permanent establishment in the province is of the total gross revenue for the year of the corporation.

(2) In subsection (1), gross revenue for the year of its permanent establishment in the province means the aggregate of the gross revenue of the corporation for the year arising from

• (a) loans secured by lands situated in the province;

• (b) loans, not secured by land, to persons residing in the province;

• (c) loans

  • (i) to persons residing in a province or country other than Canada in which the corporation has no permanent establishment, and

  • (ii) administered by a permanent establishment in the province,

  except loans secured by land situated in a province or country other than Canada in which the corporation has a permanent establishment; and

• (d) business conducted at the permanent establishment in the province, other than revenue in respect of loans.