Words and Phrases - "for the year"

S. 20(12) can provide a deduction to the extent the s. 126(1) proportionate limitation applies

1.24 If CTOP(FNBI) [Canadian tax otherwise payable that pertains to the foreign non-business income from a particular country] is less than FTP(NBIT) [non-business-income tax paid by the taxpayer for the year to the particular foreign country], it is not possible to claim the full amount of FTP(NBIT) as a subsection 126(1) foreign tax credit. This could occur because either CTOP(a) or FNBI is too low. … If an amount of what would otherwise qualify as NBIT for purposes of a foreign tax credit cannot be claimed as such, and dollar-for-dollar tax relief through a reduction to Canadian tax otherwise payable is not obtained, subsection 20(12) provides relief through a deduction in computing income.

Meaning of "paid ... for the year"

1.32 …The words, for the year relate to the year for which the taxpayer is liable to pay tax (that is, when it is exigible) to the foreign jurisdiction for the income which is considered to have been earned under the foreign jurisdiction’s tax law, even though the income may not be realized in Canada during the same tax year. Where a foreign country uses a tax year different than the tax year used in Canada, the foreign taxes actually paid must be prorated to match the Canadian tax year.

1.33 ...Any portion of a taxpayer’s foreign tax which is paid but which will be, or is, refunded to the taxpayer is not considered to be tax paid for the year.