Corporation C realized a business loss in 2006, which was carried back to 2003. Should Corporation C’s income for purposes of the M&P credit under s. 125.1(1) in 2003 (the “MPPD Amount”) be taken into account in computing its GRIP addition for 2006 ("GRIPA 2006") related to 2003? The Directorate stated:
The calculation of the GRIP addition in respect of the MPPD is described in Part 2 of Schedule 53 "General Rate Income Pool (GRIP) Calculation" in accordance with the definition of GRIP and does not take into account the amount of income of a corporation subject to MPPD (the "MPPD Amount") for a particular taxation year, regardless of whether that amount may have been taken into account in the calculation of the GRIPA 2006. …
It is clear to us, having regard to the provisions of elements I and J of element B of the formula in the definition of GRIP, that the MPPD Amount for a taxation year is not taken into account for purposes of the calculations.