(D) its total reserve liabilities as at the end of the year, and
	(E) the amount prescribed for the year in respect of the corporation, and
	(2) Subsection (1) applies
	(a) to taxation years that end after February 25, 1992; and
	(b) where a corporation so elects by notifying the Minister of National Revenue in writing before the end of the sixth month after the month in which this Act is assented to, to its 1991 and subsequent taxation years, and, where such an election is made, notwithstanding subsections 152(4) to (5) of the Act, such assessments and determinations in respect of any taxation year shall be made to the corporation's taxation years that end before February 26, 1992 as are consequential on the election.
	89. (1) The portion of paragraph 190.13(a) of the Act before subparagraph (i) is replaced by the following:
	(a) in the case of a financial institution other than a life insurance corporation, the amount, if any, by which the total at the end of the year of
	(2) The portion of paragraph 190.13(a) of the Act after subparagraph (ii) and before subparagraph (iv) is replaced by the following:
	(iii) the amount of its reserves, except to the extent that they were deducted in computing its income under Part I for the year,
	exceeds the total at the end of the year of
	(3) The portion of paragraph 190.13(b) of the Act before subparagraph (i) is replaced by the following:
	(b) in the case of a life insurance corporation that was resident in Canada at any time in the year, the amount, if any, by which the total at the end of the year of
	(4) The portion of paragraph 190.13(b) of the Act after subparagraph (ii) and before subparagraph (iii) is replaced by the following:
	exceeds the total at the end of the year of
	(5) The portion of paragraph 190.13(c) of the Act before subparagraph (ii) is replaced by the following:
	(c) in the case of a life insurance corporation that was non-resident throughout the year, the total at the end of the year of
	(i) the greater of its surplus funds derived from operations (within the meaning assigned by subsection 138(12)), computed as if no tax were payable by it under Part I.3 or this Part for the year, and its attributed surplus for the year,
	(6) Subsections (1) to (5) apply to the 1992 and subsequent taxation years.
	90. (1) The portion of subparagraph 190.14(a)(i) of the Act before clause (B) is replaced by the following:
	(i) all amounts each of which is the carrying value at the end of the year of
	(A) any share of the capital stock of the financial institution, or
	(2) Subsection (1) applies to the 1992 and subsequent taxation years.
	91. (1) The Act is amended by adding the following after section 190.15:
Capital allowance	190.16 (1) For the purposes of this Part, the capital allowance for a taxation year of a life insurance corporation that carries on business in Canada at any time in the year is the total of
	(a) $10,000,000,
	(b) 1/2 of the amount, if any, by which the lesser of
	(i) $50,000,000, and
	(ii) its taxable capital employed in Canada for the year
	exceeds $10,000,000,
	(c) 1/4 of the amount, if any, by which the lesser of
	(i) $100,000,000, and
	(ii) its taxable capital employed in Canada for the year
	exceeds $50,000,000,
	(d) 1/2 of the amount, if any, by which the lesser of
	(i) $300,000,000, and
	(ii) its taxable capital employed in Canada for the year
	exceeds $200,000,000, and
	(e) 3/4 of the amount, if any, by which its taxable capital employed in Canada for the year exceeds $300,000,000,
	unless the corporation is related at the end of the year to another life insurance corporation that carries on business in Canada, in which case, subject to subsection (4), its capital allowance for the year is nil.
Related life insurance corporation	(2) A life insurance corporation that carries on business in Canada at any time in a taxation year and that is related at the end of the year to another life insurance corporation that carries on business in Canada may file with the Minister an agreement, in prescribed form on behalf of the related group of life insurance corporations of which the corporation is a member, under which an amount that does not exceed the total of
	(a) $10,000,000,
	(b) 1/2 of the amount, if any, by which the lesser of
	(i) $50,000,000, and
	(ii) the total of all amounts, each of which is the taxable capital employed in Canada of a life insurance corporation for the year that is a member of the related group,
	exceeds $10,000,000,
	(c) 1/4 of the amount, if any, by which the lesser of
	(i) $100,000,000, and
	(ii) the total of all amounts, each of which is the taxable capital employed in Canada of a life insurance corporation for the year that is a member of the related group,
	exceeds $50,000,000,
	(d) 1/2 of the amount, if any, by which the lesser of
	(i) $300,000,000, and
	(ii) the total of all amounts, each of which is the taxable capital employed in Canada of a life insurance corporation for the year that is a member of the related group,
	exceeds $200,000,000, and
	(e) 3/4 of the amount, if any, by which the total of all amounts, each of which is the taxable capital employed in Canada of a life insurance corporation for the year that is a member of the related group, exceeds $300,000,000
	is allocated among the members of that related group for the year.
Idem	(3) The Minister may request a life insurance corporation that carries on business in Canada at any time in a taxation year and that, at the end of the year, is related to any other life insurance corporation that carries on business in Canada to file with the Minister an agreement referred to in subsection (2) and, if the corporation does not file such an agreement within 30 days after receiving the request, the Minister may allocate among the members of the related group of life insurance corporations of which the corporation is a member for the year an amount not exceeding the total of
	(a) $10,000,000,
	(b) 1/2 of the amount, if any, by which the lesser of
	(i) $50,000,000, and
	(ii) the total of all amounts, each of which is the taxable capital employed in Canada of a life insurance corporation for the year that is a member of the related group,
	exceeds $10,000,000,
	(c) 1/4 of the amount, if any, by which the lesser of
	(i) $100,000,000, and
	(ii) the total of all amounts, each of which is the taxable capital employed in Canada of a life insurance corporation for the year that is a member of the related group,
	exceeds $50,000,000,
	(d) 1/2 of the amount, if any, by which the lesser of
	(i) $300,000,000, and
	(ii) the total of all amounts, each of which is the taxable capital employed in Canada of a life insurance corporation for the year that is a member of the related group,
	exceeds $200,000,000, and
	(e) 3/4 of the amount, if any, by which the total of all amounts, each of which is the taxable capital employed in Canada of a life insurance corporation for the year that is a member of the related group, exceeds $300,000,000.
Idem	(4) For the purposes of this Part, the least amount allocated for a taxation year to a member of a related group under an agreement described in subsection (2) or by the Minister under subsection (3) is the capital allowance for that year of the member.
Provisions applicable to Part	(5) Subsections 190.15(5) and (6) apply to this section with such modifications as the circumstances require.
	(2) Subsection (1) applies
	(a) to taxation years that end after February 25, 1992; and
	(b) where a corporation elects under paragraph 88(2)(b), to its 1991 and subsequent taxation years, and, notwithstanding subsections 152(4) to (5) of the Act, such assessments and determinations in respect of any taxation year shall be made as are consequential on the application of subsection (1) to the corporation's taxation years that end before February 26, 1992.
	92. (1) Subparagraph (a)(iii) of the description of I in subsection 204.2(1.2) of the Act is replaced by the following:
	(iii) an amount transferred to the plan on behalf of the individual in accordance with any of subsections 146(16), 147(19) and 147.3(1) and (4) to (7) or in circumstances to which subsection 146(21) applies,
	(2) Subsection (1) applies to the 1992 and subsequent taxation years.
	93. (1) The portion of paragraph (g) of the definition ``foreign property'' in subsection 206(1) of the Act before subparagraph (i) is replaced by the following:
	(g) indebtedness of a non-resident person, other than indebtedness issued or guaranteed by
	(2) Subsection 206(2.1) of the Act is replaced by the following:
Exemption	(2.1) Notwithstanding section 205, subsection (2) does not apply to a trust described in paragraph 149(1)(o.4) or a corporation described in paragraph 149(1)(o.2) in respect of any month that falls within a period for which the trustee or the corporation, as the case may be, elects in accordance with subsections 259(1) and (3).
	(3) Subsection (1) applies to months after 1992.
	(4) Subsection (2) applies to the 1992 and subsequent taxation years.
	94. (1) Subsection 207.6(5) of the Act is replaced by the following:
Residents' arrangement	(5) For the purposes of this Act, where a resident's contribution has been made under a plan or arrangement (in this subsection referred to as the ``plan''),
	(a) the plan is deemed, in respect of its application to all resident's contributions made under the plan and all property that can reasonably be considered to be derived from those contributions, to be a separate arrangement (in this subsection referred to as the ``residents' arrangement'') independent of the plan in respect of its application to all other contributions and property that can reasonably be considered to derive from those other contributions;
	(b) the residents' arrangement is deemed to be a retirement compensation arrangement; and
	(c) each person and partnership to whom a contribution is made under the residents' arrangement is deemed to be a custodian of the residents' arrangement.
Resident's contribution	(5.1) For the purpose of subsection (5), ``resident's contribution'' means such part of a contribution made under a plan or arrangement (in this subsection referred to as the ``plan'') at a time when the plan would, but for paragraph (l) of the definition ``retirement compensation arrangement'' in subsection 248(1), be a retirement compensation arrangement as
	(a) is not a prescribed contribution; and
	(b) can reasonably be considered to have been made in respect of services rendered by an individual to an employer in a period
	(i) throughout which the individual was resident in Canada and rendered services to the employer that were primarily services rendered in Canada or services rendered in connection with a business carried on by the employer in Canada (or a combination of such services), and
	(ii) at the beginning of which the individual had been resident in Canada throughout at least 60 of the 72 preceding calendar months, where the individual was non-resident at any time before the period and became a member of the plan before the end of the month after the month in which the individual became resident in Canada,
	and, for the purpose of this paragraph, where benefits provided to an individual under a particular plan or arrangement are replaced by benefits under another plan or arrangement, the other plan or arrangement shall be deemed, in respect of the individual, to be the same plan or arrangement as the particular plan or arrangement.
	(2) Subsection (1) applies after October 8, 1986.
	95. (1) Subsection 209(2) of the Act is replaced by the following:
Tax	(2) Every person shall pay a tax under this Part for each taxation year equal to 45% of the total of the person's carved-out incomes for the year from carved-out properties.
	(2) Subsection (1) applies to the 1992 and subsequent taxation years.