(ii) the amount, if any, by which
	(A) the amount of prescribed assistance that the taxpayer (or a person with whom the taxpayer was not dealing at arm's length) received or is entitled to receive in respect of the share
	exceeds
	(B) the total of all amounts determined under subparagraph (i) in respect of any disposition of the share or of the property substituted for the share before the particular time by the taxpayer or by a person with whom the taxpayer was not dealing at arm's length.
	(2) Subsection (1) applies to the 1991 and subsequent taxation years.
	16. (1) The portion of subsection 43.1(1) of the Act before paragraph (a) is replaced by the following:
Life estates in real property	43.1 (1) Notwithstanding any other provision of this Act, where at any time a taxpayer disposes of a remainder interest in real property (except as a result of a transaction to which subsection 73(3) would otherwise apply or by way of a gift to a donee described in the definition ``total charitable gifts'' or ``total Crown gifts'' in subsection 118.1(1)) to a person or partnership and retains a life estate or an estate pur autre vie (in this section called the ``life estate'') in the property, the taxpayer shall be deemed
	(2) Subsection (1) applies to dispositions occurring after December 20, 1991.
	17. (1) Paragraph 44(2)(d) of the Act is replaced by the following:
	(d) the time at which the taxpayer is deemed by section 70 or paragraph 128.1(4)(b) to have disposed of the property, and
	(2) The portion of subsection 44(6) of the Act before paragraph (a) is replaced by the following:
Deemed proceeds of disposition	(6) Where a taxpayer has disposed of property that was a former business property and was in part a building and in part the land (or an interest therein) subjacent to, or immediately contiguous to and necessary for the use of, the building, for the purposes of this subdivision, the amount if any, by which
	(3) 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).
	(4) Subsection (2) applies to dispositions occurring after December 21, 1992.
	18. (1) Subsection 45(2) of the Act is replaced by the following:
Election where change of use	(2) For the purposes of this subdivision and section 13, where subparagraph (1)(a)(i) or paragraph 13(7)(b) would otherwise apply to any property of a taxpayer for a taxation year and the taxpayer so elects in respect of the property in the taxpayer's return of income for the year under this Part, the taxpayer shall be deemed not to have begun to use the property for the purpose of gaining or producing income except that, if in the taxpayer's return of income under this Part for a subsequent taxation year the taxpayer rescinds the election in respect of the property, the taxpayer shall be deemed to have begun so to use the property on the first day of that subsequent year.
	(2) Subsection (1) applies to the 1992 and subsequent taxation years.
	19. (1) Section 48 of the Act is repealed.
	(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).
	20. (1) Subsection 51(1) of the Act is replaced by the following:
Convertible property	51. (1) Where a share of the capital stock of a corporation is acquired by a taxpayer in exchange for
	(a) a capital property of the taxpayer that is another share of the corporation (in this section referred to as a ``convertible property''), or
	(b) a capital property of the taxpayer that is a bond, debenture or note of the corporation the terms of which confer on the holder the right to make the exchange (in this section referred to as a ``convertible property'')
	and no consideration other than the share is received by the taxpayer for the convertible property,
	(c) except for the purpose of subsection 20(21), the exchange shall be deemed not to be a disposition of the convertible property,
	(d) the cost to the taxpayer of all the shares of a particular class acquired by the taxpayer on the exchange shall be deemed to be the amount determined by the formula
	A x B C
	where
	A is the adjusted cost base to the taxpayer of the convertible property immediately before the exchange,
	B is the fair market value, immediately after the exchange, of all the shares of the particular class acquired by the taxpayer on the exchange, and
	C is the fair market value, immediately after the exchange, of all the shares acquired by the taxpayer on the exchange,
	(e) for the purposes of sections 74.4 and 74.5, the exchange shall be deemed to be a transfer of the convertible property by the taxpayer to the corporation, and
	(f) where the convertible property is taxable Canadian property of the taxpayer, the share acquired by the taxpayer on the exchange shall be deemed to be taxable Canadian property of the taxpayer.
	(2) Section 51 of the Act is amended by adding the following after subsection (2):
Computation of paid-up capital	(3) Where subsection (1) applies to the exchange of convertible property described in paragraph (1)(a) (referred to in this subsection as the ``old shares''), in computing the paid-up capital in respect of a particular class of shares of the capital stock of the corporation at any particular time that is the time of, or any time after, the exchange
	(a) there shall be deducted the amount determined by the formula
	(A - B) x C A
	where
	A is the total of all amounts each of which is the amount of the increase, if any, as a result of the exchange, in the paid-up capital in respect of a class of shares of the capital stock of the corporation, computed without reference to this subsection as it applies to the exchange,
	B is the paid-up capital immediately before the exchange in respect of the old shares, and
	C is the increase, if any, as a result of the exchange, in the paid-up capital in respect of the particular class of shares, computed without reference to this subsection as it applies to the exchange; and
	(b) there shall be added an amount equal to the lesser of
	(i) the amount, if any, by which
	(A) the total of all amounts deemed by subsection 84(3), (4) or (4.1) to be a dividend on shares of that class paid by the corporation before the particular time
	exceeds
	(B) the total that would be determined under clause (A) if this Act were read without reference to paragraph (a), and
	(ii) the total of all amounts required by paragraph (a) to be deducted in respect of that particular class of shares before the particular time.
Application	(4) Subsections (1) and (2) do not apply to any exchange to which subsection 85(1) or (2) or section 86 applies.
	(3) Subsection (1) and subsection 51(4) of the Act, as enacted by subsection (2), apply to exchanges occurring, and reorganizations that begin, after December 21, 1992.
	(4) Subsection 51(3) of the Act, as enacted by subsection (2), applies to exchanges occurring after August 1992, other than exchanges occurring after August 1992 and before December 21, 1992 where the corporation issuing shares on the exchange so elects in writing and files the election with the Minister of National Revenue before the end of the sixth month after the month in which this Act is assented to.
	21. (1) Section 52 of the Act is amended by adding the following after subsection (7):
Cost of shares on immigration	(8) Notwithstanding any other provision of this Act, where at any time a corporation becomes resident in Canada, the cost to any shareholder that is not at that time resident in Canada of any share of the capital stock of the corporation shall be deemed to be equal to the lesser of that cost otherwise determined and the paid-up capital in respect of the share immediately after that time.
	(2) Subsection (1) applies to dispositions occurring after 1992.
	22. (1) Clause 53(2)(k)(i)(C) of the Act is replaced by the following:
	(C) the amount of prescribed assistance that the taxpayer has received or is entitled to receive in respect of, or for the acquisition of, shares of the capital stock of a prescribed venture capital corporation or a prescribed labour-sponsored venture capital corporation or shares of the capital stock of a taxable Canadian corporation that are held in a prescribed stock savings plan, or
	(2) Subsection (1) applies to the 1991 and subsequent taxation years.
	23. (1) Paragraph (c) of the definition ``superficial loss'' in section 54 of the Act is replaced by the following:
	(c) was a disposition deemed by paragraph 33.1(11)(a), subsection 45(1), section 48 as it read in its application before 1993, section 50 or 70, subsection 104(4), section 128.1 or subsection 138(11.3), 144(4.1) or (4.2) or 149(10) to have been made,
	(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).
	24. (1) Section 55 of the Act is amended by adding the following after subsection (3):
Idem	(3.1) Notwithstanding subsection (3), a dividend to which subsection (2) would, but for paragraph (3)(b), otherwise apply is not excluded from the application of subsection (2) where the dividend is received as part of a series of transactions or events in which
	(a) a person or partnership (in this subsection referred to as the ``foreign vendor'') who, or any member of which, is resident in a country other than Canada disposes of property that is
	(i) a share of the capital stock of the particular corporation referred to in paragraph (3)(b) or of a transferee (within the meaning assigned by that paragraph) in relation to the particular corporation that is taxable Canadian property of the foreign vendor or, where the foreign vendor is a partnership, would be taxable Canadian property of the foreign vendor if the foreign vendor were non-resident, or
	(ii) property the fair market value of which, at any time during the course of the series of transactions or events, is derived principally from one or more shares which, if owned by the foreign vendor, would be shares described in subparagraph (i); and
	(b) the property disposed of by the foreign vendor or any other property acquired by any person or partnership in substitution for it is acquired by a person (other than the particular corporation) or partnership that, at any time during the course of the series of transactions or events, deals at arm's length with the foreign vendor.
	(2) Subsection (1) applies to dividends received after May 4, 1993, other than a dividend received as part of a series of transactions or events in which a foreign vendor was obliged on May 4, 1993 to dispose of property described in paragraph 55(3.1)(a) of the Act, as enacted by subsection (1), under a written agreement entered into before May 5, 1993.
	25. (1) Paragraph 56(1)(a) of the Act is amended by adding the word ``or'' at the end of subparagraph (v) and by replacing subparagraphs (vi) and (vii) with the following:
	(vi) except to the extent otherwise required to be included in computing the taxpayer's income, a prescribed benefit under a government assistance program;
	(2) Paragraph 56(1)(d.2) of the Act is replaced by the following:
Idem	(d.2) any amount received out of or under, or as proceeds of disposition of, an annuity the payment for which was
	(i) deductible in computing the taxpayer's income because of paragraph 60(l) or because of subsection 146(5.5) of the Income Tax Act, chapter 148 of the Revised Statutes of Canada, 1952, or
	(ii) made in circumstances to which subsection 146(21) applied;
	(3) Subsection 56(4) of the Act is replaced by the following:
Transfer of rights to income	(4) Where a taxpayer has, at any time before the end of a taxation year, transferred or assigned to a person with whom the taxpayer was not dealing at arm's length the right to an amount (other than any portion of a retirement pension assigned by the taxpayer under section 65.1 of the Canada Pension Plan or a comparable provision of a provincial pension plan as defined in section 3 of that Act) that would, if the right had not been so transferred or assigned, be included in computing the taxpayer's income for the taxation year, the part of the amount that relates to the period in the year throughout which the taxpayer is resident in Canada shall be included in computing the taxpayer's income for the year unless the income is from property and the taxpayer has also transferred or assigned the property.
	(4) Subparagraph 56(4.1)(b)(ii) of the Act is replaced by the following:
	(ii) property that the loan or indebtedness enabled or assisted the particular individual, or the trust in which the particular individual is beneficially interested, to acquire, or
	(5) Subsection (1) applies to benefits received after October 1991.
	(6) Subsections (2) and (3) apply to the 1992 and subsequent taxation years.
	(7) Subsection (4) applies to income relating to periods that begin after December 21, 1992.
	26. (1) Clause 60(j.2)(ii)(C) of the Act is replaced by the following:
	(C) the total of all amounts each of which is paid by the taxpayer in the year or within 60 days after the end of the year as a premium (within the meaning assigned by subsection 146(1)) under a registered retirement savings plan under which the taxpayer's spouse (or, where the taxpayer died in the year or within 60 days after the end of the year, an individual who was the taxpayer's spouse immediately before the death) is the annuitant (within the meaning assigned by subsection 146(1)), to the extent that the amount was not deducted in computing the taxpayer's income for a preceding taxation year;
	(2) The portion of clause 60(l)(v)(B.1) of the Act before subclause (I) is replaced by the following:
	(B.1) the least of
	(3) Clause 60(l)(v)(B.1) of the Act is amended by striking out the word ``and'' at the end of subclause (I) and by replacing subclause (II) with the following:
	(II) the amount (other than any portion thereof included in the amount determined under clause (B) or (B.2)) included in computing the taxpayer's income for the year as
	1. a payment (other than a payment that is part of a series of periodic payments or that relates to an actuarial surplus) received by the taxpayer out of or under a registered pension plan,
	2. a refund of premiums out of or under a registered retirement savings plan, or