(a) until such time as all the taxpayer's rights (other than a right to a share of the income or loss of the partnership under an agreement referred to in subsection 96(1.1)) to receive any property of or from the partnership in satisfaction of the taxpayer's interest in the partnership immediately before the time that the taxpayer ceased to be a member of the partnership are satisfied in full, that interest (in this section referred to as a ``residual interest'') shall, subject to sections 70 and 128.1 but notwithstanding any other section of this Act, be deemed not to have been disposed of by the taxpayer and to continue to be an interest in the partnership;
	(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).
	46. (1) Subparagraphs 104(5)(a)(i) and (ii) of the Act are replaced by the following:
	(i) the capital cost to the trust of the property on its reacquisition shall be deemed to be the amount that was the actual capital cost to the trust of the property, and
	(ii) the excess shall be deemed to have been allowed under paragraph 20(1)(a) to the trust in respect of the property in computing its income for taxation years that ended before the trust reacquired the property;
	(2) Subsection 104(22) of the Act is replaced by the following:
Designation of foreign source income by trust	(22) For the purposes of this subsection, subsection (22.1) and section 126, such portion of a trust's income for a taxation year (in this subsection referred to as ``that year'') throughout which it is resident in Canada from a source in a country other than Canada as
	(a) can reasonably be considered (having regard to all the circumstances including the terms and conditions of the trust arrangement) to be part of the income that, because of subsection (13) or (14), was included in computing the income for a particular taxation year of a particular beneficiary under the trust, and
	(b) is not designated by the trust in respect of any other beneficiary thereunder
	shall, if so designated by the trust in respect of the particular beneficiary in its return of income under this Part for that year, be deemed to be the particular beneficiary's income for the particular year from that source.
Foreign tax deemed paid by beneficiary	(22.1) Where a taxpayer is a beneficiary under a trust, for the purposes of this subsection and section 126, the taxpayer shall be deemed to have paid as business-income tax or non-business-income tax, as the case may be, for a particular taxation year in respect of a source the amount determined by the formula
	A x B C
	where
	A is the amount that, but for subsection (22.3), would be the business-income tax or non-business-income tax, as the case may be, paid by the trust in respect of the source for a taxation year (in this subsec tion referred to as ``that year'') of the trust that ends in the particular year;
	B is the amount deemed, because of a desig nation under subsection (22) for that year by the trust, to be the taxpayer's income from the source; and
	C is the trust's income for that year from the source.
Recalculation of trust's foreign source income	(22.2) For the purpose of section 126, there shall be deducted in computing a trust's income from a source for a taxation year the total of all amounts deemed, because of designations under subsection (22) by the trust for the year, to be income of beneficiaries under the trust from that source.
Recalculation of trust's foreign tax	(22.3) For the purpose of section 126, there shall be deducted in computing the business-income tax or non-business-income tax paid by a trust for a taxation year in respect of a source the total of all amounts deemed, because of designations under subsection (22) by the trust for the year, to be paid by beneficiaries under the trust as business-income tax or non-business-income tax, as the case may be, in respect of the source.
Definitions	(22.4) For the purposes of subsections (22) to (22.3), the expressions ``business-income tax'' and ``non-business-income tax'' have the meanings assigned by subsection 126(7).
	(3) Subsection (1) applies to days determined under subsection 104(4) of the Act that are after 1992.
	(4) Subsection (2) applies to taxation years that end after November 12, 1981 except that, with respect to taxation years of trusts that began before 1988, the portion of subsection 104(22) of the Act before paragraph (a), as enacted by subsection (2), shall be read as follows:
	(22) For the purposes of this subsection, subsection (22.1) and section 126, such portion of a trust's income for a taxation year (in this subsection referred to as ``that year'') from a source in a country other than Canada as
	47. (1) Paragraph 107(1)(c) of the Act is replaced by the following:
	(c) where the taxpayer is a corporation and the interest is not an interest in a prescribed trust, its capital loss from the disposition at any time of the interest or part thereof shall be deemed to be the amount, if any, by which the amount of its loss otherwise determined exceeds the amount, if any, by which
	(i) the total of all amounts each of which was received by the trust before that time (and, where the trust is a unit trust, after 1987) and designated by it under subsection 104(19) or (20) in respect of the corporation
	exceeds
	(ii) such portion of the total referred to in subparagraph (i) as can reasonably be considered to have resulted in a reduction under this paragraph of its capital loss otherwise determined from the disposition before that time of an interest in the trust,
	(2) Subsection (1) applies to the 1988 and subsequent taxation years.
	48. (1) The definitions ``eligible real property gain'', ``eligible real property loss'' and ``eligible taxable capital gains'' in subsection 108(1) of the Act are replaced by the following:
``eligible real property gain'' « gain admissible sur immeuble »	``eligible real property gain'' of a trust has the meaning that would be assigned by the definition of that expression in subsection 110.6(1) if the reference in that definition to ``non-qualifying real property'' were read as ``non-qualifying real property as defined in subsection 108(1)'';
``eligible real property loss'' « perte admissible sur immeuble »	``eligible real property loss'' of a trust has the meaning that would be assigned by the definition of that expression in subsection 110.6(1) if the reference in that definition to ``non-qualifying real property'' were read as ``non-qualifying real property as defined in subsection 108(1)'';
``eligible taxable capital gains'' « gains en capital imposables admissibles »	``eligible taxable capital gains'' of a trust for a taxation year means the lesser of
	(a) its annual gains limit for the year (within the meaning that would be assigned by the definition of that expression in subsection 110.6(1) if the reference in that definition to ``non-qualifying real property'' were read as ``non-qualifying real property as defined in subsection 108(1))'', and
	(b) the amount determined by the formula
	A - B
	where
	A is its cumulative gains limit at the end of the year (within the meaning that would be assigned by the definition of that expression in subsection 110.6(1) if the reference in that definition to ``non-qualifying real property'' were read as ``non-qualifying real property as defined in subsection 108(1))'', and
	B is the total of all amounts designated under subsection 104(21.2) by the trust in respect of beneficiaries in taxation years before that year;
	(2) Paragraph (a) of the definition ``cost amount'' in subsection 108(1) of the Act is amended by adding the word ``and'' at the end of subparagraph (i) and by replacing subparagraphs (ii) and (iii) with the following:
	(ii) all amounts each of which is the cost amount to the trust, immediately before the distribution, of each such other property, and
	(3) The description of A in paragraph (b) of the definition ``cost amount'' in subsection 108(1) of the Act is replaced by the following:
	A is the total of
	(i) all money of the trust on hand immediately before that time, and
	(ii) all amounts each of which is the cost amount to the trust, immediately before that time, of each other property of the trust,
	(4) The portion of the definition ``testamentary trust'' in subsection 108(1) of the Act before paragraph (a) is replaced by the following:
``testamentary trust'' « fiducie testamentaire »	``testamentary trust'' in a taxation year means a trust or estate that arose on and as a consequence of the death of an individual (including a trust referred to in subsection 248(9.1)), other than
	(5) Subsection (1) applies to the 1992 and subsequent taxation years.
	(6) Subsections (2) and (3) apply after July 13, 1990.
	(7) Subsection (4) applies to the 1990 and subsequent taxation years.
	49. (1) Subparagraph 110(1)(d)(iii) of the Act is replaced by the following:
	(iii) the amount payable by the taxpayer to acquire the share under the agreement (determined without reference to any change in the value of a currency of a country other than Canada relative to Canadian currency during the period between the time the agreement was made and the time the share was acquired) is not less than the amount by which
	(A) the fair market value of the share at the time the agreement was made
	exceeds
	(B) the amount, if any, paid by the taxpayer to acquire the right to acquire the share,
	or where the rights under the agreement were acquired by the taxpayer as a result of one or more dispositions of rights to which subsection 7(1.4) applied, the amount payable by the taxpayer to acquire the old share under the original option (determined without reference to any change in the value of a currency of a country other than Canada relative to Canadian currency during the period between the time the agreement was made and the time the share was acquired) that was disposed of in consideration for a new option in the first such disposition was not less than the amount by which
	(C) the fair market value of the old share at the time the agreement in respect of the original option was made
	exceeds
	(D) the amount, if any, paid by the taxpayer to acquire the right to acquire the old share, and
	(2) Subparagraph 110(1)(f)(ii) of the Act is replaced by the following:
	(ii) compensation received under an employees' or workers' compensation law of Canada or a province in respect of an injury, disability or death, except any such compensation received by a person as the employer or former employer of the person in respect of whose injury, disability or death the compensation was paid, or
	(3) Paragraph 110(1)(f) of the Act is amended by striking out the word ``or'' at the end of subparagraph (ii), by adding the word ``or'' at the end of subparagraph (iii) and by adding the following after subparagraph (iii):
	(iv) the taxpayer's income from employment with a prescribed international non-governmental organization, where the taxpayer
	(A) was not, at any time in the year, a Canadian citizen,
	(B) was a non-resident person immediately before beginning that employment in Canada, and
	(C) if the taxpayer is resident in Canada, became resident in Canada solely for the purpose of that employment,
	(4) Subsection (1) applies to the 1992 and subsequent taxation years.
	(5) Subsection (2) applies to the 1991 and subsequent taxation years.
	(6) Subsection (3) applies to the 1993 and subsequent taxation years.
	50. (1) The definitions ``annual gains limit'' and ``cumulative gains limit'' in subsection 110.6(1) of the Act are replaced by the following:
``annual gains limit'' « plafond annuel des gains »	``annual gains limit'' of an individual for a taxation year means the amount determined by the formula
	A - B
	where
	A is the lesser of
	(a) the amount determined in respect of the individual for the year under paragraph 3(b) in respect of capital gains and capital losses, and
	(b) the amount that would be determined in respect of the individual for the year under paragraph 3(b) in respect of capital gains and capital losses if
	(i) the only properties referred to in paragraph 3(b) were properties disposed of by the individual after 1984, and
	(ii) the individual's capital gains and capital losses for the year from dispositions of non-qualifying real property of the individual were equal to the individual's eligible real property gains and eligible real property losses, respectively, for the year from those dispositions, and
	B is the total of
	(a) the amount, if any, by which
	(i) the individual's net capital losses for other taxation years deducted under paragraph 111(1)(b) in computing the individual's taxable income for the year
	exceeds
	(ii) the amount,if any, by which the amount determined in respect of the individual for the year under paragraph 3(b) in respect of capital gains and capital losses exceeds the amount determined for A in respect of the individual for the year, and
	(b) all of the individual's allowable business investment losses for the year;
``cumulative gains limit'' « plafond des gains cumulatifs »	``cumulative gains limit'' of an individual at the end of a taxation year means the amount, if any, by which
	(a) the total of all amounts determined in respect of the individual for the year or preceding taxation years that end after 1984 for A in the definition ``annual gains limit''
	exceeds the total of
	(b) all amounts determined in respect of the individual for the year or preceding taxation years that end after 1984 for B in the definition ``annual gains limit'',
	(c) the amount, if any, deducted under paragraph 3(e) in computing the individual's income for the 1985 taxation year,
	(d) all amounts deducted under this section in computing the individual's taxable incomes for preceding taxation years, and