Special case	(2) Where in a taxation year a corporation
	(a) has held out the prospect that it will make allocations in proportion to patronage as described in section 135, or
	(b) is a credit union,
	and for the year or the preceding taxation year
	(2) Paragraph 157(3)(e) of the Act is replaced by the following:
	(e) 1/12 of the total of the amounts each of which is deemed by subsection 125.4(3), 127.1(1) or 127.41(3) to have been paid on account of the corporation's tax payable under this Part for the year.
	(3) Subsections (1) and (2) apply to taxation years that end after February 22, 1994, except that, for taxation years that end before 1995, paragraph 157(3)(e) of the Act, as enacted by subsection (2), shall be read without reference to subsection 125.4(3) of the Act.
	107. (1) Section 160 of the Act is amended by adding the following after subsection (1):
Joint liability where s. 69(11) applies	(1.1) Where a particular person or partner ship is deemed by subsection 69(11) to have disposed of a property at any time, the person referred to in that subsection to whom a benefit described in that subsection was available in respect of a subsequent disposi tion of the property or property substituted for the property is jointly and severally liable with each other taxpayer to pay a part of the other taxpayer's liabilities under this Act in respect of each taxation year equal to the amount determined by the formula
	A - B
	where
	A is the total of amounts payable under this Act by the other taxpayer in respect of the year, and
	B is the amount that would, if the particular person or partnership were not deemed by subsection 69(11) to have disposed of the property, be determined for A in respect of the other taxpayer in respect of the year,
	but nothing under this subsection is deemed to limit the liability of the other taxpayer under any other provision of this Act.
	(2) Subsections 160(2) and (3) of the Act are replaced by the following:
Assessment	(2) The Minister may at any time assess a taxpayer in respect of any amount payable because of this section and the provisions of this Division apply , with such modifications as the circumstances require, in respect of an assessment made under this section as though it had been made under section 152.
Discharge of liability	(3) Where a particular taxpayer has become jointly and severally liable with another taxpayer under this section in respect of part or all of a liability under this Act of the other taxpayer ,
	(a) a payment by the particular taxpayer on account of that taxpayer's liability shall to the extent of the payment discharge the joint liability; but
	(b) a payment by the other taxpayer on account of that taxpayer's liability dis charges the particular taxpayer's liability only to the extent that the payment operates to reduce that other taxpayer's liability to an amount less than the amount in respect of which the particular taxpayer is, by this section , made jointly and severally liable.
	(3) Subsection (1) applies in respect of dispositions that are deemed by subsection 69(11) of the Act to occur after April 26, 1995.
	108. (1) The portion of paragraph 161(7)(a) of the Act before subparagraph (i) is replaced by the following:
	(a) the tax payable under this Part and Parts I.3, VI and VI.1 by the taxpayer for the year is deemed to be the amount that it would be if the consequences of the deduction or exclusion of the following amounts were not taken into consideration:
	(2) Paragraph 161(7)(a) of the Act is amended by adding the following after subparagraph (viii):
	(viii.1) any amount deducted under sub section 147.2(4) in computing the tax payer's income for the year because of the application of subsection 147.2(6) as a result of the taxpayer's death in the subsequent taxation year,
	(3) Paragraph 161(7)(a) of the English version of the Act is amended by replacing the word ``or'' at the end of subparagraph (ix) with the word ``and'', by adding the word ``and'' at the end of subparagraph (x) and by repealing the portion after subpara graph (x).
	(4) The portion of paragraph 161(7)(b) of the Act before subparagraph (i) is replaced by the following:
	(b) the amount by which the tax payable under this Part and Parts I.3, VI and VI.1 by the taxpayer for the year is reduced as a consequence of the deduction or exclusion of amounts described in paragraph (a) is deemed to have been paid on account of the taxpayer's tax payable under this Part for the year on the day that is the latest of
	(5) Subsection 161(11) of the Act is amended by striking out the word ``and'' at the end of paragraph (b) and by adding the following after that paragraph:
	(b.1) in the case of a penalty under subsec tion 237.1(7.4), from the day on which the taxpayer became liable to the penalty to the day of payment; and
	(6) Section 161 of the Act is amended by adding the following after subsection (11):
Partnership liable to interest	(12) Where a partnership is liable to a penalty under subsection 237.1(7.4), sections 152, 158 to 160.1, this section and sections 164 to 167 and Division J apply, with such modifications as the circumstances require, with respect to interest on the penalty as if the partnership were a corporation.
	(7) Subsections (1), (3) and (4) apply to amounts that become payable after Decem ber 1995.
	(8) Subsection (2) applies to taxpayers who die after 1992.
	(9) Subsections (5) and (6) apply after December 1, 1994.
	109. (1) Subsection 162(9) of the Act is repealed.
	(2) Subsection (1) applies after December 1, 1994.
	110. (1) The portion of subsection 163(2) of the Act before paragraph (a) is replaced by the following:
False statements or omissions	(2) Every person who, knowingly, or under circumstances amounting to gross negligence, has made or has participated in, assented to or acquiesced in the making of, a false statement or omission in a return, form, certificate, statement or answer (in this section referred to as a ``return'') filed or made in respect of a taxation year for the purposes of this Act, is liable to a penalty of the greater of $100 and 50% of the total of
	(2) Subsection 163(4) of the Act is amended by striking out the word ``and'' at the end of paragraph (b) and by adding the following after that paragraph:
	(b.1) any amount that may be deducted under subsection 147.2(4) in computing the person's income for the year because of the application of subsection 147.2(6) as a result of the person's death in the subse quent taxation year; and
	(3) Subsection (1) applies after June 20, 1996.
	(4) Subsection (2) applies to taxpayers who die after 1992.
	111. (1) Subparagraph 164(1)(a)(i) of the Act is replaced by the following:
	(i) before mailing the notice of assess ment for the year, where the taxpayer is a qualifying corporation (as defined in subsection 127.1(2)) and claims in its return of income under this Part for the year to have paid an amount on account of its tax payable under this Part for the year by reason of subsection 127.1(1) in respect of its refundable investment tax credit (as defined in subsection 127.1(2)), refund without application therefor, all or any part of any amount claimed in the return as an overpayment for the year, not exceeding the amount by which the total determined under para graph (f) of the definition ``refundable investment tax credit'' in subsection 127.1(2) in respect of the taxpayer for the year exceeds the total determined under paragraph (g) of that definition in respect of the taxpayer for the year, and
	(2) Paragraph 164(1)(b) of the Act is replaced by the following:
	(b) shall, with all due dispatch, make the refund referred to in subparagraph (a)(ii) after mailing the notice of assessment if application for it is made in writing by the taxpayer within the period within which the Minister would be allowed under subsec tion 152(4) to assess tax payable under this Part by the taxpayer for the year if that subsection were read without reference to paragraph 152(4)(a) .
	(3) Subsection 164(2.1) of the Act is replaced by the following:
Application respecting refunds under s. 122.5	(2.1) Where an amount deemed under section 122.5 to be paid by an individual during a month specified for a taxation year is applied under subsection (2) to a liability of the individual and the individual's return of income for the year is filed on or before the individual's balance-due day for the year, the amount is deemed to have been so applied on the day on which the amount would have been refunded if the individual were not liable to make a payment to Her Majesty in right of Canada .
	(4) Subsection 164(5) of the Act is amended by adding the following after paragraph (h):
	(h.01) the deduction of an amount under subsection 147.2(4) in computing the tax payer's income for the year because of the application of subsection 147.2(6) as a result of the taxpayer's death in the follow ing taxation year,
	(5) Subsection 164(5.1) of the Act is amended by adding the following after paragraph (h):
	(h.01) the deduction of an amount under subsection 147.2(4) in computing the tax payer's income for the year because of the application of subsection 147.2(6) as a result of the taxpayer's death in the follow ing taxation year,
	(6) Paragraph 164(6)(c) of the Act is replaced by the following:
	(c) such parts of one or more capital losses of the estate from the disposition of proper ties in the year (the total of which is not to exceed the excess referred to in paragraph (a) ) as the legal representative so elects, in prescribed manner and within a prescribed time, are deemed (except for the purpose of subsection 112(3) and this paragraph) to be capital losses of the deceased taxpayer from the disposition of the properties by the taxpayer in the taxpayer's last taxation year and not to be capital losses of the estate from the disposition of those properties,
	(7) Subsection (1) applies to taxation years that end after December 2, 1992.
	(8) Subsection (2) applies after April 27, 1989.
	(9) Subsections (4) and (5) apply to taxpayers who die after 1992.
	(10) Subsection (6) applies to deaths that occur after 1993.
Transitional provision	112. Where
	(a) the first taxation year of an estate of an individual ends after April 26, 1995 and before 1997,
	(b) the estate has a capital loss from the disposition after the year and before 1997 of a share of the capital stock of a corporation that was owned by the indi vidual or the estate on April 26, 1995 and acquired by the estate as a consequence of the individual's death, and
	(c) the individual's legal representative so elects in writing filed with the Minister of National Revenue within 6 months after the month in which this Act is assented to,
	the following rules apply:
	(d) the disposition is deemed to have occurred in the first taxation year of the estate,
	(e) an election under paragraph 164(6)(c) of the Act for the year is deemed to have been filed on time if it is filed with the Minister of National Revenue within 6 months after the month in which this Act is assented to, and
	(f) an amended return of income under Part I of the Act for the individual's last taxation year is deemed for the purposes of paragraph 164(6)(e) of the Act to have been filed on time if it is filed with the Minister of National Revenue within 6 months after the month in which this Act is assented to.
	113. (1) The portion of subsection 165(1.1) of the Act before paragraph (b) is replaced by the following:
Limitation of right to object to assessments or determina- tions	(1.1) Notwithstanding subsection (1), where at any time the Minister assesses tax, interest, penalties or other amounts payable under this Part by, or makes a determination in respect of, a taxpayer
	(a) under subsection 67.5(2) or 152(1.8) , subparagraph 152(4)(b)(i) or subsection 152(4.3) or (6), 164(4.1), 220(3.4) or 245(8) or in accordance with an order of a court vacating, varying or restoring the assess ment or referring the assessment back to the Minister for reconsideration and reassess ment,
	(2) The portion of subsection 165(1.1) of the Act after paragraph (c) is replaced by the following:
	the taxpayer may object to the assessment or determination within 90 days after the day of mailing of the notice of assessment or deter mination, but only to the extent that the rea sons for the objection can reasonably be re garded
	(d) where the assessment or determination was made under subsection 152(1.8), as relating to any matter or conclusion speci fied in paragraph 152(1.8)(a), (b) or (c), and
	(e) in any other case, as relating to any matter that gave rise to the assessment or determination
	and that was not conclusively determined by the court, and this subsection shall not be read or construed as limiting the right of the tax payer to object to an assessment or a deter mination issued or made before that time.
	(3) Section 165 of the Act is amended by adding the following after subsection (1.14):
Partnership	(1.15) Notwithstanding subsection (1), where the Minister makes a determination under subsection 152(1.4) in respect of a fiscal period of a partnership, an objection in respect of the determination may be made only by one member of the partnership, and that member must be either
	(a) designated for that purpose in the information return made under section 229 of the Income Tax Regulations for the fiscal period; or
	(b) otherwise expressly authorized by the partnership to so act.
	(4) Subsections 165(3.1) and (3.2) of the Act are repealed.
	(5) Subsection 165(5) of the Act is re placed by the following:
Validity of reassessment	(5) The limitations imposed under subsec tions 152(4) and (4.01) do not apply to a reassessment made under subsection (3).
	(6) Subsections (1) to (3) apply in respect of determinations made after the day on which this Act is assented to.
	(7) Subsection (4) applies after August 27, 1995.
	(8) Subsection (5) applies after April 27, 1989.
	114. (1) The portion of subsection 169(2) of the Act before paragraph (b) is replaced by the following:
Limitation of right to appeal from assessments or determina- tions	(2) Notwithstanding subsection (1), where at any time the Minister assesses tax, interest, penalties or other amounts payable under this Part by, or makes a determination in respect of, a taxpayer
	(a) under subsection 67.5(2) or 152(1.8) , subparagraph 152(4)(b)(i) or subsection 152(4.3) or (6), 164(4.1), 220(3.4) or 245(8) or in accordance with an order of a court vacating, varying or restoring the assess ment or referring the assessment back to the Minister for reconsideration and reassess ment,
	(2) The portion of subsection 169(2) of the Act after paragraph (c) is replaced by the following: