Subsection 180.1(2)
Administrative Policy
7 September 2000 External T.I. 2000-0017015 F - CALCUL DE LA SURTAXE
surtax computed on the higher of the Division E and E.1 amounts, both computed before deduction of the foreign tax credit and overseas employment tax credit
An individual’s federal tax payable (under Division E) before the foreign overseas employment tax credit of $6,000 and a foreign tax credit of $1,000, was $10,000, and his minimum tax (under Division E.1) before the foreign tax credit was $5,000.
CCRA indicated that the tax payable computed under s. 180.1(2) would be $10,000 given that the tax was to be computed pursuant to Division E and Division E.1 without taking into account ss. 122.3 and 126(1) and as “the tax (as calculated under paragraph 180.1(2)(b)) under Division E is higher than that calculated under Division E.1, the surtax would therefore be calculated on the amount in Division E.”