the taxpayer may appeal to the Tax Court of Canada within the time limit specified in sub section (1), but only to the extent that the rea sons for the appeal can reasonably be regarded
	(d) where the assessment or determination was made under subsection 152(1.8), as relating to any matter specified in para graph 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 appeal from an assessment or a deter mination issued or made before that time.
	(3) Subsections (1) and (2) apply in respect of determinations made after the day on which this Act is assented to.
	115. (1) Paragraphs 181.1(7)(a) and (b) of the Act are replaced by the following:
	(a) the corporation's unused surtax credit for a particular taxation year that ended before that time is deductible by the corpo ration for a taxation year that ends after that time (in this paragraph referred to as the ``subsequent year'') to the extent of that proportion of the corporation's Canadian surtax payable for the particular year that
	(i) the amount, if any, by which
	(A) the total of all amounts each of which is
	(I) its income under Part I for the particular year from a business that was carried on by the corporation throughout the subsequent year for profit or with a reasonable expecta tion of profit , or
	(II) where properties were sold, leased, rented or developed or ser vices were rendered in the course of carrying on that business before that time, its income under Part I for the particular year from any other busi ness all or substantially all of the income of which was derived from the sale, leasing, rental or develop ment, as the case may be, of similar properties or the rendering of simi lar services
	exceeds
	(B) the total of all amounts each of which is an amount deducted under paragraph 111(1)(a) or (d) in comput ing its taxable income for the particu lar year in respect of a non-capital loss or a farm loss, as the case may be, for a taxation year in respect of any business referred to in clause (A)
	is of the greater of
	(ii) the amount determined under sub paragraph (i), and
	(iii) the corporation's taxable income for the particular year; and
	(b) the corporation's unused surtax credit for a particular taxation year that ends after that time is deductible by the corporation for a taxation year that ended before that time (in this paragraph referred to as the ``preceding year'') to the extent of that proportion of the corporation's Canadian surtax payable for the particular year that
	(i) the amount, if any, by which
	(A) the total of all amounts each of which is
	(I) its income under Part I for the particular year from a business that was carried on by the corporation in the preceding year and throughout the particular year for profit or with a reasonable expectation of profit, or
	(II) where properties were sold, leased, rented or developed or ser vices were rendered in the course of carrying on that business before that time, the corporation's income un der Part I for the particular year from any other business all or substantial ly all of the income of which was derived from the sale, leasing, rental or development, as the case may be, of similar properties or the render ing of similar services
	exceeds
	(B) the total of all amounts each of which is an amount deducted under paragraph 111(1)(a) or (d) in comput ing the corporation's taxable income for the particular year in respect of a non-capital loss or a farm loss, as the case may be, for a taxation year in respect of any business referred to in clause (A)
	is of the greater of
	(ii) the amount determined under sub paragraph (i), and
	(iii) the corporation's taxable income for the particular year.
	(2) Subsection (1) applies to acquisitions of control that occur after April 26, 1995.
	116. (1) Subsection 181.2(3) of the Act is amended by adding the following after paragraph (b):
	(b.1) the amount of its deferred unrealized foreign exchange gains at the end of the year,
	(2) Paragraph 181.2(3)(g) of the Act is replaced by the following:
	(g) where the corporation was a member of a partnership at the end of the year, that proportion of the amount, if any, by which
	(i) the total of all amounts (other than amounts owing to the member or to other corporations that are members of the partnership) that would be determined under this paragraph and paragraphs (b) to (d) and (f) in respect of the partnership at the end of its last fiscal period that ends in the year (if paragraphs (b) to (d) and (f) applied to partnerships in the same way that they apply to corporations )
	exceeds
	(ii) the amount of the partnership's deferred unrealized foreign exchange losses at the end of that period
	that the member's share of the partnership's income or loss for that period is of the partnership's income or loss for that period
	(3) Subsection 181.2(3) of the Act is amended by striking out the word ``and'' at the end of paragraph (i), by adding the word ``and'' at the end of paragraph (j) and by adding the following after paragraph (j):
	(k) the amount of its deferred unrealized foreign exchange losses at the end of the year.
	(4) Subsections (1) to (3) apply to the 1995 and subsequent taxation years.
	117. (1) Subparagraph 181.3(3)(d)(i) of the Act is replaced by the following:
	(i) the amount that is the greater of
	(A) the amount, if any, by which
	(I) the corporation's surplus funds derived from operations (as defined in subsection 138(12)) as of the end of the year, computed as if no tax were payable under this Part or Part VI for the year
	exceeds the total of all amounts each of which is
	(II) an amount on which the corpo ration was required to pay, or would but for subsection 219(5.2) have been required to pay, tax under Part XIV for a preceding taxation year, except the portion, if any, of the amount on which tax was payable, or would have been payable, be cause of subparagraph 219(4)(a)(i.1), and
	(III) an amount on which the corpo ration was required to pay, or would but for subsection 219(5.2) have been required to pay, tax under subsection 219(5.1) for the year because of the transfer of an insur ance business to which subsection 138(11.5) or (11.92) has applied, and
	(B) the corporation' s attributed sur plus for the year,
	(2) Subsection (1) applies to the 1994 and subsequent taxation years.
	118. (1) Subparagraph 181.4(d)(i) of the Act is replaced by the following:
	(i) is a ship or aircraft operated by the corporation in international traffic or is personal property used in its business of transporting passengers or goods by ship or aircraft in international traffic, and
	(2) Subsection (1) applies to the 1995 and subsequent taxation years.
	119. (1) The portion of subsection 181.5(6) of the Act after paragraph (b) is replaced by the following:
	are , for the purposes of this section and sub section 181.3(4), deemed not to be related to each other except that, where at any time a tax payer has a right referred to in paragraph 251(5)(b) with respect to shares and it can rea sonably be considered that one of the main purposes for the acquisition of the right was to avoid any limitation on the amount of a corpo ration's capital deduction for a taxation year, for the purpose of determining whether a cor poration is related to any other corporation, the corporations are, for the purposes of this section, deemed to be in the same position in relation to each other as if the right were im mediate and absolute and as if the taxpayer had exercised the right at that time .
	(2) Subsection (1) applies after April 26, 1995.
	120. (1) The Act is amended by adding the following after section 181.7:
Provisions applicable - Crown corporations	181.71 Section 27 applies to this Part with any modifications that the circumstances require.
	(2) Subsection (1) applies to taxation years that end after June 1989.
	121. (1) Paragraph 186.1(b) of the Act is replaced by the following:
	(b) that was, throughout the year,
	(i) a bank,
	(ii) a corporation licensed or otherwise authorized under the laws of Canada or a province to carry on in Canada the business of offering to the public its services as a trustee,
	(iii) an insurance corporation,
	(iv) a prescribed labour-sponsored ven ture capital corporation,
	(v) a prescribed investment contract corporation, or
	(vi) a non-resident-owned investment corporation.
	(2) Subsection (1) applies after February 22, 1994.
	122. (1) The Act is amended by adding the following after section 187.6:
Provisions applicable - Crown corporations	187.61 Section 27 applies to this Part with any modifications that the circumstances require.
	(2) Subsection (1) applies after 1987.
	123. (1) Paragraphs 190.1(6)(a) and (b) of the Act are replaced by the following:
	(a) the corporation's unused Part I tax credit and unused surtax credit for a particular taxation year that ended before that time is deductible by the corporation for a taxation year that ends after that time (in this paragraph referred to as the ``subsequent year'') to the extent of that proportion of the corporation's tax payable under Part I for the particular year that
	(i) the amount, if any, by which
	(A) the total of all amounts each of which is
	(I) its income under Part I for the particular year from a business that was carried on by the corporation for profit or with a reasonable expectation of profit throughout the subsequent year, or
	(II) where properties were sold, leased, rented or developed or ser vices were rendered in the course of carrying on that business before that time, its income under Part I for the particular year from any other busi ness all or substantially all of the income of which was derived from the sale, leasing, rental or develop ment, as the case may be, of similar properties or the rendering of simi lar services
	exceeds
	(B) the total of all amounts each of which is an amount deducted under paragraph 111(1)(a) or (d) in comput ing its taxable income for the particu lar year in respect of a non-capital loss or a farm loss, as the case may be, for a taxation year in respect of any business referred to in clause (A)
	is of the greater of
	(ii) the amount determined under sub paragraph (i), and
	(iii) the corporation's taxable income for the particular year; and
	(b) the corporation's unused Part I tax credit and unused surtax credit for a particular taxation year that ends after that time is deductible by the corporation for a taxation year (in this paragraph referred to as the ``preceding year'') that ended before that time to the extent of that proportion of the corporation's tax payable under Part I for the particular year that
	(i) the amount, if any, by which
	(A) the total of all amounts each of which is
	(I) its income under Part I for the particular year from a business that was carried on by the corporation in the preceding year and throughout the particular year for profit or with a reasonable expectation of profit , or
	(II) where properties were sold, leased, rented or developed or ser vices were rendered in the course of carrying on that business before that time, its income under Part I for the particular year from any other busi ness all or substantially all of the income of which was derived from the sale, leasing, rental or develop ment, as the case may be, of similar properties or the rendering of simi lar services
	exceeds
	(B) the total of all amounts each of which is an amount deducted under paragraph 111(1)(a) or (d) in comput ing its taxable income for the particu lar year in respect of a non-capital loss or a farm loss, as the case may be, for a taxation year in respect of any business referred to in clause (A)
	is of the greater of
	(ii) the amount determined under sub paragraph (i), and
	(iii) the corporation's taxable income for the particular year.
	(2) Subsection (1) applies to acquisitions of control that occur after April 26, 1995.
	124. (1) Subparagraph 190.13(c)(i) of the Act is replaced by the following:
	(i) the amount that is the greater of
	(A) the amount, if any, by which
	(I) its surplus funds derived from operations (as defined in subsection 138(12)) as of the end of the year , computed as if no tax were payable under Part I.3 or this Part for the year
	exceeds the total of all amounts each of which is
	(II) an amount on which it was required to pay, or would but for subsection 219(5.2) have been re quired to pay, tax under Part XIV for a preceding taxation year, except the portion, if any, of the amount on which tax was payable, or would have been payable, because of sub paragraph 219(4)(a)(i.1), and