96. (1) The portion of paragraph 210(d) of the Act before subparagraph (i) is replaced by the following:
	(d) a trust resident in Canada (other than a testamentary trust, a mutual fund trust or a trust exempt, because of subsection 149(1), from tax under Part I on all or part of its taxable income), if
	(2) Subsection (1) applies to the 1993 and subsequent taxation years.
	97. (1) Paragraph 212(1)(b) of the Act is amended by striking out the word ``and'' at the end of subparagraph (x), by adding the word ``and'' at the end of subparagraph (xi) and by adding the following after subparagraph (xi):
	(xii) interest payable under a securities lending arrangement by a lender under the arrangement that is a financial institution prescribed for the purpose of clause (iii)(D), or a person resident in Canada who is registered or licensed under the laws of a province to trade in securities, on money provided to the lender either as collateral or as consideration for the particular security lent or transferred under the arrangement where
	(A) the particular security is an obligation referred to in subparagraph (ii) or an obligation of the government of any country, province, state, municipality or other political subdivision,
	(B) the amount of money so provided at any time during the term of the arrangement does not exceed 110% of the fair market value at that time of the particular security, and
	(C) the arrangement was neither intended, nor made as a part of a series of securities lending arrangements, loans or other transactions that was intended, to be in effect for more than 270 days,
	(2) Clause 212(1)(h)(iii.1)(A) of the Act is replaced by the following:
	(A) because of subsection 146(21) or 147.3(9) would not, if the non-resident person had been resident in Canada throughout the taxation year in which the payment was made, be included in computing the non-resident person's income, or
	(3) Paragraph 212(1)(h) of the Act is amended by striking out the word ``or'' at the end of subparagraph (iii.2), by adding the word ``or'' at the end of subparagraph (iv) and by adding the following after subparagraph (iv):
	(iv.1) the portion of the payment that is transferred by the payer on behalf of the non-resident person, pursuant to an authorization in prescribed form, to acquire an annuity contract in circumstances to which subsection 146(21) applies,
	(4) Section 212 of the Act is amended by adding the following after subsection (2):
Replacement obligations	(3) For the purpose of subparagraph (1)(b)(vii), an obligation (in this subsection referred to as the ``replacement obligation'') issued by a corporation resident in Canada wholly or in substantial part and either directly or indirectly in exchange or substitution for an obligation or a part of an obligation (in this subsection referred to as the ``former obligation'') shall, where
	(a) the replacement obligation was issued
	(i) as part of a proposal to, or an arrangement with, its creditors that was approved by a court under the Bankruptcy and Insolvency Act,
	(ii) at a time when all or substantially all of its assets were under the control of a receiver, receiver-manager, sequestrator or trustee in bankruptcy, or
	(iii) at a time when, because of financial difficulty, the issuing corporation or another corporation resident in Canada with which it does not deal at arm's length was in default, or could reasonably be expected to default, on the former obligation,
	(b) the proceeds from the issue of the replacement obligation can reasonably be regarded as having been used by the issuing corporation or another corporation with which it does not deal at arm's length in the financing of its active business carried on in Canada immediately before the time when the replacement obligation was issued, and
	(c) all interest on the former obligation was (or would be, if the person to whom that interest was paid or credited were non-resident) exempt from tax under this Part because of subparagraph (1)(b)(vii),
	be deemed to have been issued when the former obligation was issued.
	(5) The portion of subsection 212(18) of the Act before paragraph (b) is replaced by the following:
Return by financial institution or securities trader	(18) Every person who in a taxation year is a prescribed financial institution for the purpose of clause (1)(b)(iii)(D) or a person resident in Canada who is registered or licensed under the laws of a province to trade in securities shall
	(a) within 6 months after the end of the year file with the Minister a return in prescribed form if in the year the person paid or credited an amount to a non-resident person in respect of which the non-resident person is, because of clause (1)(b)(iii)(D) or subparagraph (1)(b)(xii), not liable to pay tax under this Part; and
	(6) Section 212 of the Act is amended by adding the following after subsection (18):
Tax on securities traders	(19) Every taxpayer resident in Canada who is registered or licensed under the laws of one or more provinces to trade in securities shall pay a tax under this Part equal to the amount determined by the formula
	1 x .25 x (A - B) x C 365
	where
	A is the total of all amounts each of which is the amount of money provided before the end of a day to the taxpayer (and not returned or repaid before the end of the day) by or on behalf of a non-resident person as collateral or as consideration for a security that was lent or transferred under a securities lending arrangement described in subparagraph (1)(b)(xii),
	B is the total of
	(a) all amounts each of which is the amount of money provided before the end of the day by or on behalf of the taxpayer (and not returned or repaid before the end of the day) to a non-resident person as collateral or as consideration for a security described in clause (1)(b)(xii)(A) that was lent or transferred under a securities lending arrangement, and
	(b) the greater of
	(i) 10 times the greatest amount determined under those laws to be the capital employed by the taxpayer at the end of the day, and
	(ii) 20 times the greatest amount of capital required under those laws to be maintained by the taxpayer as a margin in respect of securities described in clause (1)(b)(xii)(A) at the end of the day, and
	C is the prescribed rate of interest in effect for the day,
	and shall remit that amount to the Receiver General on or before the 15th day of the month after the month in which the day occurs.
	(7) Subsections (1) and (6) apply to securities lending arrangements entered into after May 28, 1993.
	(8) Subsections (2) and (3) apply to payments made after August 1992.
	(9) Subsection (4) applies to replacement obligations issued after June 1993.
	(10) Subsection (5) applies to taxation years that end after May 28, 1993.
	98. (1) Paragraph 214(3)(c) of the Act is replaced by the following:
	(c) where, because of subsection 146(8.1), (8.8), (8.91), (9), (10) or (12), an amount would, if Part I applied, be required to be included in computing a taxpayer's income, that amount shall be deemed to have been paid to the taxpayer as a payment under a registered retirement savings plan or an amended plan (within the meaning assigned by subsection 146(12)), as the case may be;
	(2) Paragraph 214(3)(i) of the Act is replaced by the following:
	(i) where, because of subsection 146.3(4), (6), (6.1), (7) or (11), an amount would, if Part I applied, be required to be included in computing a taxpayer's income, that amount shall be deemed to have been paid to the taxpayer as a payment under a registered retirement income fund;
	(3) Subsections (1) and (2) apply to payments made after 1992.
	99. (1) Section 219.1 of the Act is replaced by the following:
Corporate emigration	219.1 Where at any time a corporation ceases to be a Canadian corporation, it shall, on or before the day on or before which it is required to file a return of income under Part I for its last taxation year that began before that time, pay a tax under this Part for that year equal to 25% of the amount, if any, by which the fair market value at that time of all the property owned by the corporation exceeds the total of
	(a) the paid-up capital in respect of all the issued and outstanding shares of the capital stock of the corporation at that time, and
	(b) all amounts, other than amounts payable by the corporation in respect of dividends and amounts payable under this section, each of which is the amount of any debt owing by the corporation, or any other obligation of the corporation to pay an amount, that is outstanding at that time.
	(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).
	100. (1) Section 219.2 of the Act is replaced by the following:
Limitation on rate of branch tax	219.2 Notwithstanding any other provision of this Act, where an agreement or convention between the Government of Canada and the government of another country that has the force of law in Canada
	(a) does not limit the rate of tax under this Part on corporations resident in that other country, and
	(b) provides that, where a dividend is paid by a corporation resident in Canada to a corporation resident in that other country that owns all of the shares of the capital stock of the corporation resident in Canada, the rate of tax imposed on the dividend shall not exceed a specified rate,
	any reference in section 219 to a rate of tax shall, in respect of a taxation year of a corporation to which that agreement or convention applies on the last day of that year, be read as a reference to the specified rate.
Effect of tax agreement or convention	219.3 For the purpose of section 219.1, where an agreement or convention between the Government of Canada and the government of another country that has the force of law in Canada provides that, where a dividend is paid by a corporation resident in Canada to a corporation resident in that other country that owns all of the shares of the capital stock of the corporation resident in Canada, the rate of tax imposed on the dividend shall not exceed a specified rate, the reference in section 219.1 to a rate of tax shall, in respect of a corporation that ceased to be a Canadian corporation and to which the agreement or convention applies on the first day of the taxation year after the taxation year in which the corporation ceased to be a Canadian corporation, be read as a reference to the specified rate unless, having regard to all the circumstances, it can reasonably be concluded that one of the main reasons for the corporation becoming resident in that other country was to reduce the amount of tax payable under this Part or Part XIII.
	(2) Subsection (1) applies to the 1985 and subsequent taxation years except that, in applying section 219.3 of the Act, as enacted by subsection (1), to taxation years that end before July 1993, it shall be read without reference to the words ``unless, having regard to all the circumstances, it can reasonably be concluded that one of the main reasons for the corporation becoming resident in that other country was to reduce the amount of tax payable under this Part or Part XIII''.
	101. (1) Subsection 224(1) of the Act is replaced by the following:
Garnishment	224. (1) Where the Minister has knowledge or suspects that a person is, or will be within one year, liable to make a payment to another person who is liable to make a payment under this Act (in this subsection and subsections (1.1) and (3) referred to as the ``tax debtor''), the Minister may in writing require the person to pay forthwith, where the moneys are immediately payable, and in any other case as and when the moneys become payable, the moneys otherwise payable to the tax debtor in whole or in part to the Receiver General on account of the tax debtor's liability under this Act.
	(2) The portion of subsection 224(1.1) of the Act after paragraph (b) is replaced by the following:
	the Minister may in writing require the institution or person, as the case may be, to pay in whole or in part to the Receiver General on account of the tax debtor's liability under this Act the moneys that would otherwise be so lent, advanced or paid and any moneys so paid to the Receiver General shall be deemed to have been lent, advanced or paid, as the case may be, to the tax debtor.
	(3) The portion of subsection 224(1.2) of the Act before paragraph (a) is replaced by the following:
Idem	(1.2) Notwithstanding any other provision of this Act, the Bankruptcy and Insolvency Act, any other enactment of Canada, any enactment of a province or any law, but subject to subsections 69(1) and 69.1(1) of the Bankruptcy and Insolvency Act, where the Minister has knowledge or suspects that a particular person is, or will become within one year, liable to make a payment
	(4) The portion of subsection 224(1.2) of the Act after paragraph (b) is replaced by the following:
	the Minister may in writing require the particular person to pay forthwith, where the moneys are immediately payable, and in any other case as and when the moneys become payable, the moneys otherwise payable to the tax debtor or the secured creditor in whole or in part to the Receiver General on account of the tax debtor's liability under subsection 227(10.1) or the similar provision, and on receipt of that requirement by the particular person, the amount of those moneys that is so required to be paid to the Receiver General shall, notwithstanding any security interest in those moneys, become the property of Her Majesty to the extent of that liability as assessed by the Minister and shall be paid to the Receiver General in priority to any such security interest.
	(5) Section 224 of the Act is amended by adding the following after subsection (1.3):
Garnishment	(1.4) Provisions of this Act that provide that a person who has been required to do so by the Minister must pay to the Receiver General an amount that would otherwise be lent, advanced or paid to a taxpayer who is liable to make a payment under this Act, or to that taxpayer's secured creditor, apply to Her Majesty in right of Canada or a province.
	(6) Subsection 224(3) of the Act is replaced by the following:
Idem	(3) Where the Minister has, under this section, required a person to pay to the Receiver General on account of a liability under this Act of a tax debtor moneys otherwise payable by the person to the tax debtor as interest, rent, remuneration, a dividend, an annuity or other periodic payment, the requirement applies to all such payments to be made by the person to the tax debtor until the liability under this Act is satisfied and operates to require payments to the Receiver General out of each such payment of such amount as is stipulated by the Minister in the requirement.
	(7) Subsections 224(5) and (6) of the Act are replaced by the following:
Service of garnishee	(5) Where a person carries on business under a name or style other than the person's own name, notification to the person of a requirement under subsection (1), (1.1) or (1.2) may be addressed to the name or style under which the person carries on business and, in the case of personal service, shall be deemed to be validly served if it is left with an adult person employed at the place of business of the addressee.
Idem	(6) Where persons carry on business in partnership, notification to the persons of a requirement under subsection (1), (1.1) or (1.2) may be addressed to the partnership name and, in the case of personal service, shall be deemed to be validly served if it is served on one of the partners or left with an adult person employed at the place of business of the partnership.
	(8) Subsections (1), (2), (4), (6) and (7) apply to requirements and notifications made after 1992 except that, in applying subsection 224(1) of the Act, as enacted by subsection (1), to requirements and notifications made on or before the day this Act is assented to, the reference in that subsection to ``one year'' shall be read as ``90 days''.
	(9) Subsection (3) applies to requirements and notifications made after the day this Act is assented to.
	102. (1) Subsection 224.3(1) of the Act is replaced by the following:
Payment of moneys seized from tax debtor	224.3 (1) Where the Minister has knowledge or suspects that a particular person is holding moneys that were seized by a police officer in the course of administering or enforcing the criminal law of Canada from another person (in this section referred to as the ``tax debtor'') who is liable to make a payment under this Act or under an Act of a province with which the Minister of Finance has entered into an agreement for the collection of taxes payable to the province under that Act and that are restorable to the tax debtor, the Minister may in writing require the particular person to turn over the moneys otherwise restorable to the tax debtor in whole or in part to the Receiver General on account of the tax debtor's liability under this Act or under the Act of the province, as the case may be.
	(2) Subsection (1) applies to requirements made after 1992.
	103. Paragraphs 225.1(8)(a) and (b) of the Act are replaced by the following:
	(a) a corporation by which tax under Part I.3 is payable,
	(i) where the particular year ended before July 1989, for its first taxation year that ends after June 1989, or
	(ii) where the particular year ended after June 1989, for the particular year,
	or would, but for subsection 181.1(4), have been so payable, or