(iii) the corporation's cumulative Canadian development expense at the particular time (within the meaning assigned by subsection 66.2(5)), and
	(iv) the corporation's cumulative Canadian oil and gas property expense at the particular time (within the meaning assigned by subsection 66.4(5)), and
	(d) the total of all amounts each of which is the paid-up capital in respect of a share of the capital stock of another corporation resident in Canada and connected with the corporation (within the meaning that would be assigned by subsection 186(4) if the references therein to ``payer corporation'' and ``particular corporation'' were read as references to the other corporation and the corporation, respectively) immediately after the particular time, owned by the corporation at the particular time.
Idem	(3) In computing the paid-up capital at any time in respect of a class of shares of the capital stock of a corporation, there shall be added an amount equal to the lesser of
	(a) the amount, if any, by which
	(i) the total of all amounts deemed by subsection 84(3), (4) or (4.1) to be a dividend on shares of the class paid before that time by the corporation
	exceeds
	(ii) the total that would be determined under subparagraph (i) if this Act were read without reference to subsection (2), and
	(b) the total of all amounts required by subsection (2) to be deducted in computing the paid-up capital in respect of that class of shares before that time.
Emigration	(4) For the purposes of this Act, where at a particular time a taxpayer ceases to be resident in Canada,
Year-end, fiscal period	(a) where the taxpayer is a corporation or a trust,
	(i) the taxpayer's taxation year that would otherwise include the particular time shall be deemed to have ended immediately before the particular time and a new taxation year of the taxpayer shall be deemed to have begun at the particular time, and
	(ii) for the purpose of determining the taxpayer's fiscal period after the particular time, the taxpayer shall be deemed not to have established a fiscal period before the particular time;
Deemed disposition	(b) the taxpayer shall be deemed to have disposed, at the time (in this paragraph and paragraph (d) referred to as the ``time of disposition'') that is immediately before the time that is immediately before the particular time, of each property owned by the taxpayer, other than
	(i) where the taxpayer is an individual, property that would be taxable Canadian property if the taxpayer had been resident in Canada at no time in the taxpayer's last taxation year that began before the particular time,
	(ii) where the taxpayer is an individual, property that is described in the inventory of a business carried on by the taxpayer in Canada at the particular time,
	(iii) where the taxpayer is an individual, a right to receive a payment described in any of paragraphs 212(1)(h) and (j) to (q) or a right to receive any payment of a benefit under the Canada Pension Plan or a provincial pension plan as defined in section 3 of that Act,
	(iv) where the taxpayer is an individual other than a trust, each capital property not described in any of subparagraphs (i) to (iii) in respect of which, on or before the taxpayer's balance-due day for the taxation year in which the taxpayer ceased to be resident in Canada, the taxpayer elects in prescribed manner and furnishes to the Minister security acceptable to the Minister for the payment of the additional tax that would be payable by the taxpayer under this Part for the year had the taxpayer not so elected,
	(v) where the taxpayer is an individual other than a trust and was, during the 10 years preceding the particular time, resident in Canada for a period or periods totalling 60 months or less, property that was
	(A) owned by the taxpayer at the time the taxpayer last became resident in Canada, or
	(B) acquired by the taxpayer by inheritance or bequest after the taxpayer last became resident in Canada, and
	(vi) a right to acquire shares of the capital stock of a corporation where section 7 would apply if the taxpayer disposed of the right to a person with whom the taxpayer was dealing at arm's length,
	for proceeds equal to its fair market value at the time of disposition, which proceeds shall be deemed to have become receivable and to have been received by the taxpayer at the time of disposition;
Reacquisition	(c) the taxpayer shall be deemed to have reacquired, at the particular time, each property deemed by paragraph (b) to have been disposed of by the taxpayer, at a cost equal to the proceeds of disposition of the property;
Individual	(d) notwithstanding paragraphs (b) and (c), where a taxpayer who is an individual other than a trust so elects in prescribed manner, on or before the taxpayer's balance-due day for the taxation year that includes the particular time, in respect of any property described in subparagraph (b)(i) or (ii), the taxpayer shall be deemed to have disposed of the property at the time of disposition for proceeds equal to its fair market value at that time, and to have reacquired the property at the particular time at a cost equal to those proceeds;
Deemed property	(e) capital property in respect of which a taxpayer elects under subparagraph (b)(iv) shall be deemed to be taxable Canadian property of the taxpayer from the particular time until the earlier of
	(i) the time when the taxpayer disposes of the property, and
	(ii) the time when the taxpayer next becomes resident in Canada; and
Losses on election	(f) where a taxpayer elects under subparagraph (b)(iv) or paragraph (d),
	(i) the taxpayer's income for the taxation year that includes the particular time shall be deemed to be the greater of
	(A) that income otherwise determined, and
	(B) the lesser of
	(I) that income determined without reference to this subsection, and
	(II) that income determined without reference to subparagraph (b)(iv) and paragraph (d), and
	(ii) the amount of each of the taxpayer's non-capital loss, net capital loss, restricted farm loss, farm loss and limited partnership loss for the taxation year that includes the particular time shall be deemed to be the lesser of
	(A) that amount otherwise determined, and
	(B) the greater of
	(I) that amount determined without reference to this subsection, and
	(II) that amount determined without reference to subparagraph (b)(iv) and paragraph (d).
Cross-border mergers	128.2 (1) Where a corporation formed at a particular time by the amalgamation or merger of, or by a plan of arrangement or other corporate reorganization in respect of, 2 or more corporations (each of which is referred to in this section as a ``predecessor'') is at the particular time resident in Canada, a predecessor that was not immediately before the particular time resident in Canada shall be deemed to have become resident in Canada immediately before the particular time.
Idem	(2) Where a corporation formed at a particular time by the amalgamation or merger of, or by a plan of arrangement or other corporate reorganization in respect of, 2 or more corporations is at the particular time not resident in Canada, a predecessor that was immediately before the particular time resident in Canada shall be deemed to have ceased to be resident in Canada immediately before the particular time.
Windings-up excluded	(3) For greater certainty, subsections (1) and (2) do not apply to reorganizations occurring solely because of the acquisition of property of one corporation by another corporation, pursuant to the purchase of the property by the other corporation or because of the distribution of the property to the other corporation on the winding-up of the corporation.
	(2) Subsection (1) applies after 1992 except that, where a corporation elects in accordance with paragraph 111(4)(a), subsection (1) applies to the corporation from the corporation's time of continuation (within the meaning assigned by that paragraph).
	63. (1) The portion of paragraph (b) of the definition ``non-qualifying real property'' in subsection 131(6) of the Act after subparagraph (ii) is replaced by the following:
	principally in an active business carried on by the corporation or a corporation related to it, but not including a share of the capital stock of a corporation the fair market value of which is derived principally from real property owned by another corporation the shares of which would, if owned by the corporation or the trust, not be non-qualifying real property of the corporation or the trust,
	(2) Subsection (1) applies to the 1992 and subsequent taxation years.
	64. (1) Subsections 137(4.1) and (4.2) of the Act are replaced by the following:
Payments in respect of shares	(4.1) Notwithstanding any other provision of this Act, an amount paid or payable by a credit union to a member thereof in respect of a share of a class of the capital stock of the credit union (other than any such amount paid or payable as or on account of a reduction of the paid-up capital, redemption, acquisition or cancellation of the share by the credit union to the extent of the paid-up capital of the share) shall, where the share is not listed on a prescribed stock exchange, be deemed to have been paid or payable, as the case may be, by the credit union as interest and to have been received or to have been receivable, as the case may be, by the member as interest.
Deemed interest not a dividend	(4.2) Notwithstanding any other provision of this Act, an amount that is deemed by subsection (4.1) to be interest shall be deemed not to be a dividend.
	(2) Subsection (1) applies to transactions occurring after December 21, 1992.
	65. (1) The portion of subsection 137.1(5.1) of the Act before paragraph (a) is replaced by the following:
Deeming provision	(5.1) For the purposes of this section, other than subsection (2), paragraph (3)(d), subparagraph (3)(e)(i), subsection (9) and paragraph 11(a), a subsidiary wholly-owned corporation of a particular corporation described in the definition ``deposit insurance corporation'' in subsection (5) shall be deemed to be a deposit insurance corporation, and any member institution of the particular corporation shall be deemed to be a member institution of the subsidiary, where all or substantially all of the property of the subsidiary has at all times since the subsidiary was incorporated consisted of
	(2) Subsection (1) applies to the 1992 and subsequent taxation years.
	66. (1) The description of F in the definition ``surplus funds derived from operations'' in subsection 138(12) of the Act is replaced by the following:
	F is the total of
	(a) all taxes payable under this Part by the insurer, and all income taxes payable by it under the laws of each province, for each taxation year in the period, except such portion thereof as would not have been payable by it if subsection (7) had not been enacted, and
	(b) all taxes payable under Parts I.3 and VI by the insurer for each taxation year in the period,
	(2) Subsection (1) applies to the 1992 and subsequent taxation years.
	67. (1) Subsection 143(1) of the Act is amended by striking out the word ``and'' at the end of paragraph (i), by adding the word ``and'' at the end of paragraph (j) and by adding the following after paragraph (j):
	(k) where the congregation or one of the business agencies is a corporation, section 15.1 shall, except for the purposes of paragraphs 15.1(2)(a) and (c) (other than subparagraphs 15.1(2)(c)(i) and (ii)), apply as if this subsection were read without reference to paragraphs (d) and (g).
	(2) Subsection (1) applies to the 1992 and subsequent taxation years.
	68. (1) Subsections 144(1) and (2) of the Act are replaced by the following:
Definition of ``employees profit sharing plan''	144. (1) In this section, an ``employees profit sharing plan'' at a particular time means an arrangement
	(a) under which payments computed by reference to
	(i) an employer's profits from the employer's business,
	(ii) the profits from the business of a corporation with which the employer does not deal at arm's length, or
	(iii) any combination of the amounts described in paragraphs (a) and (b)
	are required to be made by the employer to a trustee under the arrangement for the benefit of employees of the employer or of a corporation with which the employer does not deal at arm's length; and
	(b) in respect of which the trustee has, since the later of the beginning of the arrangement and the end of 1949, allocated, either contingently or absolutely, to those employees
	(i) in each year that ended at or before the particular time, all amounts received in the year by the trustee from the employer or from a corporation with which the employer does not deal at arm's length,
	(ii) in each year that ended at or before the particular time, all profits for the year from the property of the trust (determined without regard to any capital gain made by the trust or capital loss sustained by it at any time after 1955),
	(iii) in each year that ended after 1971 and at or before the particular time, all capital gains and capital losses of the trust for the year,
	(iv) in each year that ended after 1971, before 1993 and at or before the particular time, 100/15 of the total of all amounts each of which is deemed by subsection (9) to be paid on account of tax under this Part in respect of an employee because the employee ceased to be a beneficiary under the plan in the year, and
	(v) in each year that ended after 1991 and at or before the particular time, the total of all amounts each of which is an amount that an employee is entitled to deduct under subsection (9) in computing income because the employee ceased to be a beneficiary under the plan in the year.
No tax while trust governed by plan	(2) No tax is payable under this Part by a trust on the taxable income of the trust for a taxation year throughout which the trust is governed by an employees profit sharing plan.
	(2) Subsection 144(3) of the Act is amended by adding the word ``or'' at the end of paragraph (d), by striking out the word ``or'' at the end of paragraph (e) and by repealing paragraph (f).
	(3) Subsection 144(8.2) of the Act is repealed.
	(4) Subsections 144(9) and (10) of the Act are replaced by the following:
Deduction for forfeited amounts	(9) Where a person ceases at any time in a taxation year to be a beneficiary under an employees profit sharing plan and does not become a beneficiary under the plan after that time and in the year, there may be deducted in computing the person's income for the year the amount determined by the formula
	A - B - C - D 4
	where
	A is the total of all amounts each of which is an amount included in computing the per son's income for the year or a preceding taxation year (other than an amount re ceived before that time under the plan or an amount under the plan that the person is entitled at that time to receive) because of an allocation (other than an allocation to which subsection (4) applies) to the person made contingently under the plan before that time;
	B is the portion, if any, of the value of A that is included in the value of A because of paragraph 82(1)(b);
	C is the total of all taxable dividends deemed to be received by the person because of al locations under subsection (8) in respect of the plan; and
	D is the total of all amounts deductible under this subsection in computing the person's income for a preceding taxation year be cause the person ceased to be a beneficiary under the plan in a preceding taxation year.
Payments out of profits	(10) Where the terms of an arrangement under which an employer makes payments to a trustee specifically provide that the payments shall be made ``out of profits'', the arrangement shall, if the employer so elects in prescribed manner, be deemed, for the purpose of subsection (1), to be an arrangement under which payments computed by reference to the employer's profits are required.
	(5) Subsection 144(1) of the Act, as enacted by subsection (1), and subsection 144(10) of the Act, as enacted by subsection (4), apply to the 1992 and subsequent taxation years and, where an amount was paid to a person before 1993 without first having been allocated to the person, it shall be deemed for the purpose of subsection 144(1) of the Act, as enacted by subsection (1), to have been allocated to that person.