(ii) a property that is identical to the substituted property and that was ac quired after the day that is 31 days before the period begins,
	(d) at which the substituted property is not eligible capital property in respect of a business carried on by the transferor or a person affiliated with the transferor,
	(e) at which the substituted property would, if it were owned by the transferor, be deemed by section 128.1 or subsection 149(10) to have been disposed of by the transferor,
	(f) that is immediately before control of the transferor is acquired by a person or group of persons, where the transferor is a corpo ration, or
	(g) at which the winding-up of the transfer or begins (other than a winding-up to which subsection 88(1) applies), where the trans feror is a corporation.
Deemed identical property	(13) For the purpose of subsection (12),
	(a) a right to acquire a property (other than a right, as security only, derived from a mortgage, agreement for sale or similar obligation) is deemed to be a property that is identical to the property; and
	(b) where a partnership otherwise ceases to exist at any time after the disposition, the partnership is deemed not to have ceased to exist, and each person who, immediately before the partnership would, but for this paragraph, have ceased to exist, was a member of the partnership is deemed to remain a member of the partnership, until the time that is immediately after the first time described in paragraphs (12)(c) to (g).
	(6) Subsections (1) and (2) apply to fiscal periods that end after February 22, 1994, otherwise than solely because of an election under subsection 25(1) of the Act.
	(7) Subsections (3) and (4) apply to dispositions of former properties that occur after the 1993 taxation year.
	(8) Subject to section 156, subsection (5) applies to dispositions of property that occur after April 26, 1995.
	9. (1) Subsection 15(2) of the Act is replaced by the following:
Shareholder debt	(2) Where a person (other than a corpora tion resident in Canada) or a partnership (other than a partnership each member of which is a corporation resident in Canada) is
	(a) a shareholder of a particular corpora tion,
	(b) connected with a shareholder of a particular corporation, or
	(c) a member of a partnership, or a benefi ciary of a trust, that is a shareholder of a particular corporation
	and the person or partnership has in a taxation year received a loan from or has become in debted to the particular corporation, any other corporation related to the particular corpora tion or a partnership of which the particular corporation or a corporation related to the par ticular corporation is a member, the amount of the loan or indebtedness is included in com puting the income for the year of the person or partnership.
	(2) Section 15 of the Act is amended by adding the following after subsection (2.1):
Where s. 15(2) not to apply: non-resident persons	(2.2) Subsection (2) does not apply to indebtedness between non-resident persons.
Where s. 15(2) not to apply: ordinary lending business	(2.3) Subsection (2) does not apply to a debt that arose in the ordinary course of the creditor's business or a loan made in the ordinary course of the lender's ordinary business of lending money, where, at the time the indebtedness arose or the loan was made, bona fide arrangements were made for repay ment of the debt or loan within a reasonable time.
Where s. 15(2) not to apply: certain employees	(2.4) Subsection (2) does not apply to a loan made or a debt that arose
	(a) in respect of an individual who is an employee of the lender or creditor but not a specified employee of the lender or credi tor,
	(b) in respect of an individual who is an employee of the lender or creditor or who is the spouse of an employee of the lender or creditor to enable or assist the individual to acquire a dwelling or a share of the capital stock of a cooperative housing corporation acquired for the sole purpose of acquiring the right to inhabit a dwelling owned by the corporation, where the dwelling is for the individual's habitation,
	(c) where the lender or creditor is a particular corporation, in respect of an employee of the particular corporation or of another corporation that is related to the particular corporation, to enable or assist the employee to acquire from the particular corporation, or from another corporation related to the particular corporation, pre viously unissued fully paid shares of the capital stock of the particular corporation or the related corporation, as the case may be, to be held by the employee for the em ployee's own benefit, or
	(d) in respect of an employee of the lender or creditor to enable or assist the employee to acquire a motor vehicle to be used by the employee in the performance of the duties of the employee's office or employment,
	where
	(e) it is reasonable to conclude that the employee or the employee's spouse re ceived the loan, or became indebted, be cause of the employee's employment and not because of any person's share-holdings, and
	(f) at the time the loan was made or the debt was incurred, bona fide arrangements were made for repayment of the loan or debt within a reasonable time.
Where s. 15(2) not to apply: certain trusts	(2.5) Subsection (2) does not apply to a loan made or a debt that arose in respect of a trust, where
	(a) the lender or creditor is a private corporation;
	(b) the corporation is the settlor and sole beneficiary of the trust;
	(c) the sole purpose of the trust is to facilitate the purchase and sale of the shares of the corporation, or of another corporation related to the corporation, for an amount equal to their fair market value at the time of the purchase or sale, as the case may be, from or to the employees of the corporation or of the related corporation (other than employees who are specified employees of the corporation or of another corporation related to the corporation), as the case may be; and
	(d) at the time the loan was made or the debt incurred, bona fide arrangements were made for repayment of the loan or debt within a reasonable time.
Where s. 15(2) not to apply: repayment within one year	(2.6) Subsection (2) does not apply to a loan or an indebtedness repaid within one year after the end of the taxation year of the lender or creditor in which the loan was made or the indebtedness arose, where it is established, by subsequent events or otherwise, that the repayment was not part of a series of loans or other transactions and repayments.
Employee of partnership	(2.7) For the purpose of this section, an individual who is an employee of a partner ship is deemed to be a specified employee of the partnership where the individual is a specified shareholder of one or more corpora tions that, in total, are entitled, directly or indirectly, to a share of any income or loss of the partnership, which share is not less than 10% of the income or loss.
	(3) Subsection 15(8) of the Act is re pealed.
	(4) Subsection 15(9) of the English ver sion of the Act is replaced by the following:
Deemed benefit to shareholder by corporation	(9) Where an amount in respect of a loan or debt is deemed by section 80.4 to be a benefit received by a person or partnership in a taxation year, the amount is deemed for the purpose of subsection (1) to be a benefit conferred in the year on a shareholder, unless subsection 6(9) or paragraph 12(1)(w) applies to the amount .
	(5) Subsections (1) to (3) apply to loans made and indebtedness arising in the 1990 and subsequent taxation years, except that
	(a) in its application to loans made and indebtedness arising before April 26, 1995, subsection 15(2.4) of the Act, as enacted by subsection (2), shall be read without reference to paragraph (e); and
	(b) in its application to loans made and indebtedness arising before June 20, 1996, subsection 15(2.5) of the Act, as enacted by subsection (2), shall be read without reference to ``(other than em ployees who are specified employees of the corporation or of another corpora tion related to the corporation)''.
	(6) Subsection (4) applies to taxation years that end after November 1991.
	10. (1) The definition ``majority interest partner'' in subsection 15.1(3) of the Act is repealed.
	(2) Subsection (1) applies after April 26, 1995.
	11. (1) The definition ``majority interest partner'' in subsection 15.2(3) of the Act is repealed.
	(2) Subsection (1) applies after April 26, 1995.
	12. (1) The portion of subsection 18(9.1) of the Act before paragraph (a) is replaced by the following:
Penalties, bonuses and rate- reduction payments	(9.1) Subject to subsection 142.4(10), where at any time a payment, other than a payment that
	(2) Subsection 18(13) of the Act is re placed by the following:
Where superficial loss rules apply to money lenders	(13) Subsection (15) applies, subject to subsection 142.6(7), where
	(a) a taxpayer (in this subsection and subsection (15) referred to as the ``transfer or'') disposes of a particular property;
	(b) the disposition is not described in any of paragraphs (c) to (g) of the definition ``superficial loss'' in section 54;
	(c) the transferor is not an insurer;
	(d) the ordinary business of the transferor includes the lending of money and the particular property was used or held in the ordinary course of that business;
	(e) the particular property is a share, or a loan, bond, debenture, mortgage, note, agreement for sale or any other indebted ness;
	(f) the particular property was not a capital property of the transferor;
	(g) during the period that begins 30 days before and ends 30 days after the disposi tion, the transferor or a person affiliated with the transferor acquires a property (in this subsection and subsection (15) referred to as the ``substituted property'') that is, or is identical to, the particular property; and
	(h) at the end of the period, the transferor or a person affiliated with the transferor owns the substituted property.
Where superficial loss rules apply to adventurers in trade	(14) Subsection (15) applies where
	(a) a person (in this subsection and subsec tion (15) referred to as the ``transferor'') disposes of a particular property;
	(b) the particular property is described in an inventory of a business that is an adventure or concern in the nature of trade;
	(c) the disposition is not a disposition that is deemed to have occurred by section 70, subsection 104(4), section 128.1, paragraph 132.2(1)(f) or subsection 138(11.3) or 149(10);
	(d) during the period that begins 30 days before and ends 30 days after the disposi tion, the transferor or a person affiliated with the transferor acquires property (in this subsection and subsection (15) referred to as the ``substituted property'') that is, or is identical to, the particular property; and
	(e) at the end of the period, the transferor or a person affiliated with the transferor owns the substituted property.
Superficial loss rules	(15) Where this subsection applies because of subsection (13) or (14) to a disposition of a particular property,
	(a) the transferor's loss, if any, from the disposition is deemed to be nil, and
	(b) the amount of the transferor's loss, if any, from the disposition (determined with out reference to this subsection) is deemed to be a loss of the transferor from a disposition of the particular property at the first time, after the disposition,
	(i) at which a 30-day period begins throughout which neither the transferor nor a person affiliated with the transferor owns
	(A) the substituted property, or
	(B) a property that is identical to the substituted property and that was ac quired after the day that is 31 days before the period begins,
	(ii) at which the substituted property would, if it were owned by the transferor, be deemed by section 128.1 or subsection 149(10) to have been disposed of by the transferor,
	(iii) that is immediately before control of the transferor is acquired by a person or group of persons, where the transferor is a corporation, or
	(iv) at which the winding-up of the transferor begins (other than a winding- up to which subsection 88(1) applies), where the transferor is a corporation,
	and for the purpose of paragraph (b), where a partnership otherwise ceases to exist at any time after the disposition, the partnership is deemed not to have ceased to exist, and each person who was a member of the partnership immediately before the partnership would, but for this subsection, have ceased to exist is deemed to remain a member of the partner ship, until the time that is immediately after the first time described in subparagraphs (b)(i) to (iv).
Deemed identical property	(16) For the purposes of subsections (13), (14) and (15), a right to acquire a property (other than a right, as security only, derived from a mortgage, agreement for sale or similar obligation) is deemed to be a property that is identical to the property.
	(3) Subsection (1) applies to taxation years that end after February 22, 1994.
	(4) Subject to section 156, subsection 18(13) of the Act, as enacted by subsection (2), applies to dispositions of property that occur after April 26, 1995, other than a disposition that occurred before July 1995 to which subsection 142.6(7) of the Act
	(a) does not apply; and
	(b) would apply if the disposition had occurred after June 1995.
	(5) Subsection 18(14) of the Act, as enacted by subsection (2), applies to disposi tions of property that occur after June 20, 1996, other than a disposition that occurs before 1997 to a person or partnership that was obliged on June 20, 1996 to acquire the property pursuant to the terms of an agreement in writing made on or before that day, and for the purposes of this subsection, a person or partnership shall be considered not to be obliged to acquire property where the person or partnership can be excused from performing the obliga tion if there is a change to the Act or if there is an adverse assessment under the Act.
	(6) Subsections 18(15) and (16) of the Act, as enacted by subsection (2), apply to dispositions of property that occur after April 26, 1995.
	13. (1) The portion of paragraph 20(1)(e) of the Act after subparagraph (ii.2) and before subparagraph (iii) is replaced by the following:
	(including a commission, fee or other amount paid or payable for or on account of services rendered by a person as a salesper son, agent or dealer in securities in the course of the issuance, sale or borrowing, but not including any amount that is paid or payable as or on account of the principal amount of the indebtedness or as or on account of interest) that is the lesser of
	(2) The portion of subparagraph 20(1)(l)(ii) of the Act before clause (A) is replaced by the following:
	(ii) where the taxpayer is a financial institution (as defined in subsection 142.2(1)) in the year or a taxpayer whose ordinary business includes the lending of money , an amount in respect of proper ties (other than mark-to-market proper ties, as defined in that subsection) that are doubtful loans or lending assets that were made or acquired by the taxpayer in the ordinary course of the taxpayer's business of insurance or the lending of money or that were specified debt obliga tions (as defined in that subsection) of the taxpayer , equal to the total of
	(3) Sub-subclause 20(1)(l)(ii)(B)(II)2 of the Act is replaced by the following:
	2. the total of all amounts in cluded under subsection 12(3) or paragraph 142.3(1)(a) in com puting the taxpayer's income for the year or a preceding taxation year to the extent that those amounts reduced the part of the reserve referred to in sub-sub clause 1