(b) the total amount of taxes that would be determined under paragraph (a) if paragraphs 107(2)(a) to (c) had applied to each distribution by the trust in the year of property to which paragraph (1)(a) applies.
Inadequate security	(4.62) Subject to subsection (4.7), where it is determined at any particular time that security accepted by the Minister under subsection (4.6) is not adequate to secure the particular amount for which it was furnished by or on behalf of a trust,
	(a) subject to a subsequent application of this subsection, the security shall be considered after the particular time to secure only the amount for which it is adequate security at the particular time;
	(b) the Minister shall notify the trust in writing of the determination and shall accept adequate security, for all or any part of the particular amount, furnished by or on behalf of the trust within 90 days after the notification; and
	(c) any security accepted in accordance with paragraph (b) is deemed to have been accepted by the Minister under subsection (4.6) on account of the particular amount at the particular time.
Extension of time	(4.63) Where in the opinion of the Minister it would be just and equitable to do so, the Minister may at any time extend
	(a) the time for making an election under subsection (4.6);
	(b) the time for furnishing and accepting security under subsection (4.6); or
	(c) the 90-day period for the acceptance of the security under paragraph (4.62)(b).
Undue hardship	(4.7) If, in respect of any period of time, the Minister determines that an individual who has made an election under either subsection (4.5) or (4.6)
	(a) cannot, without undue hardship, pay or reasonably arrange to have paid on the individual's behalf, an amount of taxes to which security under that subsection would relate, and
	(b) cannot, without undue hardship, provide or reasonably arrange to have provided on the individual's behalf, adequate security under that subsection,
	the Minister may, in respect of the election, accept for the period security different from, or of lesser value than, that which the Minister would otherwise accept under that subsection.
Limit	(4.71) In making a determination under subsection (4.7), the Minister shall ignore any transaction that is a disposition, lease, encumbrance, mortgage, hypothec, or other voluntary restriction by a person or partnership of the person's or partnership's rights in respect of a property, if the transaction can reasonably be considered to have been entered into for the purpose of influencing the determination.
	(2) Subsection (1) applies to dispositions and distributions that occur at any time after October 1, 1996 except that,
	(a) the reference to ``$50,000'' in paragraph 220(4.51)(a) of the Act, as enacted by subsection (1), shall be read as a reference to ``$75,000'' in respect of emigration years that are before 2001; and
	(b) if an individual ceased to be resident in Canada, or a distribution by a trust occurred to which paragraph 220(4.6)(a) of the Act, as enacted by subsection (1), applies in respect of the trust, before the particular day on which this Act receives royal assent,
	(i) an election by the individual under subsection 220(4.5) of the Act, or by the trust under subsection 220(4.6) of the Act, as the case may be, as enacted by subsection (1), in respect of the taxation year that includes that time is deemed to have been made in a timely manner if it is made on or before the individual's filing-due date for the taxation year that includes the particular day, and
	(ii) security furnished by or on behalf of the individual under subsection 220(4.5) of the Act, or by or on behalf of the trust under subsection 220(4.6) of the Act, as the case may be, as enacted by subsection (1), is deemed to have been furnished in a timely manner if it is furnished on or before the individual's filing-due date for the taxation year that includes the particular day.
	179. Paragraph 225.1(6)(b) of the Act is replaced by the following:
	(b) an amount required to be deducted or withheld, and required to be remitted or paid, under this Act or the Regulations ;
	180. (1) Section 227 of the Act is amended by adding the following after subsection (4.2):
Application to Crown	(4.3) For greater certainty, subsections (4) to (4.2) apply to Her Majesty in right of Canada or a province where Her Majesty in right of Canada or a province is a secured creditor (within the meaning assigned by subsection 224(1.3)) or holds a security interest (within the meaning assigned by that subsection).
	(2) Subsection 227(16) of the Act is replaced by the following:
Municipal or provincial corporation excepted	(16) A corporation that at any time in a taxation year would be a corporation described in any of paragraphs 149(1)(d) to (d.6) but for a provision of an appropriation Act is deemed not to be a private corporation for the purposes of Part IV with respect to that year.
	(3) Subsection (2) applies to taxation years that begin after 1998.
	181. The portion of section 231 of the Act before the definition ``authorized person'' is replaced by the following:
Definitions	231. In sections 231.1 to 231.7 ,
	182. Subsection 231.5(2) of the Act is replaced by the following:
Compliance	(2) No person shall, physically or otherwise, interfere with, hinder or molest an official (in this subsection having the meaning assigned by subsection 241(10)) doing anything that the official is authorized to do under this Act or attempt to interfere with, hinder or molest any official doing or prevent or attempt to prevent an official from doing, anything that the official is authorized to do under this Act , and every person shall, unless the person is unable to do so, do everything that the person is required to do by or under subsection (1) or sections 231.1 to 231.4.
	183. The Act is amended by adding the following after section 231.6:
Compliance order	231.7 (1) On summary application by the Minister, a judge may, notwithstanding subsection 238(2), order a person to provide any access, assistance, information or document sought by the Minister under section 231.1 or 231.2 if the judge is satisfied that
	(a) the person was required under section 231.1 or 231.2 to provide the access, assistance, information or document and did not do so; and
	(b) in the case of information or a document, the information or document is not protected from disclosure by solicitor-client privilege (within the meaning of subsection 232(1)).
Notice required	(2) An application under subsection (1) must not be heard before the end of five clear days from the day the notice of application is served on the person against whom the order is sought.
Judge may impose conditions	(3) A judge making an order under subsection (1) may impose any conditions in respect of the order that the judge considers appropriate.
Contempt of court	(4) If a person fails or refuses to comply with an order, a judge may find the person in contempt of court and the person is subject to the processes and the punishments of the court to which the judge is appointed.
Appeal	(5) An order by a judge under subsection (1) may be appealed to a court having appellate jurisdiction over decisions of the court to which the judge is appointed. An appeal does not suspend the execution of the order unless it is so ordered by a judge of the court to which the appeal is made.
	184. (1) The definition ``specified foreign property'' in subsection 233.3(1) of the Act is amended by adding the following after paragraph (o):
	(o.1) a right with respect to, or indebtedness of, an authorized foreign bank that is issued by, and payable or otherwise enforceable at, a branch in Canada of the bank.
	(2) Subsection (1) applies after June 27, 1999.
	185. Paragraph 239(2.21)(a) of the Act is replaced by the following:
	(a) to whom taxpayer information has been provided for a particular purpose under paragraph 241(4)(b), (c), (e), (h), (k), (n), (o) or (p) .
	186. (1) The portion of subsection 241(3.2) of the Act before paragraph (a) is replaced by the following:
Registered charities	(3.2) An official may provide to any person the following taxpayer information relating to another person that was at any time a registered charity (in this subsection referred to as the ``charity''):
	(2) Subsection 241(4) of the Act is amended by striking out the word ``or'' at the end of paragraph (m), by adding the word ``or'' at the end of paragraph (n) and by adding the following after paragraph (n):
	(o) to provide taxpayer information to any person solely for the purpose of enabling the Chief Statistician, within the meaning assigned by section 2 of the Statistics Act, to provide to a statistical agency of a province data concerning business activities carried on in the province, where the information is used by the agency solely for research and analysis and the agency is authorized under the law of the province to collect the same or similar information on its own behalf in respect of such activities; and
	(p) provide taxpayer information to a police officer (within the meaning assigned by subsection 462.48(17) of the Criminal Code) solely for the purpose of investigating whether an offence has been committed under the Criminal Code, or the laying of an information or the preferring of an indictment, where
	(i) such information can reasonably be regarded as being necessary for the purpose of ascertaining the circumstances in which an offence under the Criminal Code may have been committed, or the identity of the person or persons who may have committed an offence, with respect to an official, or with respect to any person related to that official,
	(ii) the official was or is engaged in the administration or enforcement of this Act, and
	(iii) the offence can reasonably be considered to be related to that administration or enforcement.
	(3) Paragraph 241(4)(o) of the Act, as enacted by subsection (2), applies after this Act receives royal assent to information relating to the 1997 and subsequent taxation years and, for the purpose of subsection 17(2) of the Statistics Act, where such information was collected before this Act receives royal assent, the information is deemed to have been collected at the time at which it is provided to a provincial agency pursuant to paragraph 241(4)(o) of the Income Tax Act, as enacted by subsection (2).
	187. (1) The definition ``transfer pricing capital adjustment'' in subsection 247(1) of the Act is replaced by the following:
``transfer pricing capital adjustment'' « redressemen t de capital »	``transfer pricing capital adjustment'' of a taxpayer for a taxation year means the total of
	(a) all amounts each of which is
	(i) 1/2 of the amount, if any, by which the adjusted cost base to the taxpayer of a capital property (other than a depreciable property) is reduced in the year because of an adjustment made under subsection (2),
	(ii) 3/4 of the amount, if any, by which the adjusted cost base to the taxpayer of an eligible capital expenditure of the taxpayer in respect of a business is reduced in the year because of an adjustment made under subsection (2), or
	(iii) the amount, if any, by which the capital cost to the taxpayer of a depreciable property is reduced in the year because of an adjustment made under subsection (2); and
	(b) all amounts each of which is that proportion of the total of
	(i) 1/2 of the amount, if any, by which the adjusted cost base to a partnership of a capital property (other than a depreciable property) is reduced in a fiscal period that ends in the year because of an adjustment made under subsection (2),
	(ii) 3/4 of the amount, if any, by which the adjusted cost base to a partnership of an eligible capital expenditure of the partnership in respect of a business is reduced in a fiscal period that ends in the year because of an adjustment made under subsection (2), and
	(iii) the amount, if any, by which the capital cost to a partnership of a depreciable property is reduced in the period because of an adjustment made under subsection (2),
	that
	(iv) the taxpayer's share of the income or loss of the partnership for the period
	is of
	(v) the income or loss of the partnership for the period,
	and where the income and loss of the partnership are nil for the period, the income of the partnership for the period is deemed to be $1,000,000 for the purpose of determining a taxpayer's share of the partnership's income for the purpose of this definition.
	(2) Subsection 247(4) of the French version of the Act is replaced by the following:
Documenta- tion ponctuelle	(4) Pour l'application du paragraphe (3) et de la définition de « arrangement admissible de participation au coût » au paragraphe (1), un contribuable ou une société de personnes est réputé ne pas avoir fait d' efforts sérieux pour déterminer et utiliser les prix de transfert de pleine concurrence ou les attributions de pleine concurrence relativement à une opération ou ne pas avoir pris part à une opération qui est un arrangement admissible de participation au coût, à moins d'avoir à la fois :
	a) établi ou obtenu , au plus tard à la date limite de production qui lui est applicable pour l'année d'imposition ou l'exercice, selon le cas, au cours duquel l'opération est conclue, des registres ou des documents contenant une description complète et exacte, quant à tous les éléments importants, de ce qui suit :
	(i) les biens ou les services auxquels l'opération se rapporte,
	(ii) les modalités de l'opération et leurs rapports éventuels avec celles de chacune des autres opérations conclues entre les participants à l'opération,
	(iii) l'identité des participants à l'opération et les liens qui existent entre eux au moment de la conclusion de l'opération,
	(iv) les fonctions exercées, les biens utilisés ou apportés et les risques assumés dans le cadre de l'opération par les participants,
	(v) les données et méthodes prises en considération et les analyses effectuées en vue de déterminer les prix de transfert, l'attribution des bénéfices ou des pertes ou la participation aux coûts, selon le cas, relativement à l'opération,
	(vi) les hypothèses, stratégies et principes éventuels ayant influé sur l'établissement des prix de transfert, l'attribution des bénéfices ou des pertes ou la participation aux coûts relativement à l'opération;
	b) pour chaque année d'imposition ou exercice ultérieur où se poursuit l'opération, établi ou obtenu , au plus tard à la date limite de production qui lui est applicable pour l'année ou l'exercice, selon le cas, des registres ou des documents contenant une description complète et exacte de chacun des changements importants dont les éléments visés aux sous-alinéas a)(i) à (vi) ont fait l'objet au cours de l'année ou de l'exercice relativement à l'opération;
	c) fourni les registres ou documents visés aux alinéas a) et b) au ministre dans les trois mois suivant la signification à personne ou par courrier recommandé ou certifié d'une demande écrite les concernant.
	(3) Subsection (1) applies to taxation years that end after February 27, 2000 except that, for a taxation year of a taxpayer that includes either February 28, 2000 or October 17, 2000 or began after February 28, 2000 or ended before October 17, 2000, the reference to the fraction ``1/2'' in the definition ``transfer pricing capital adjustment'' in subsection 247(1) of the Act, as enacted by subsection (1), shall be read as a reference to the fraction in paragraph 38(a) of the Act, as enacted by subsection 22(1), that applies to the taxpayer for the year.
	(4) Subsection (2) applies in respect of adjustments made under subsection 247(2) of the Act for taxation years and fiscal periods that begin after 1998, except that
	(a) subsection (2) does not apply to transactions completed before September 11, 1997; and
	(b) a record or document made, obtained or provided to the Minister of National Revenue by a taxpayer or a partnership on or before the taxpayer's or partnership's documentation-due date for the taxpayer's or partnership's first taxation year or fiscal period, as the case may be, that begins after 1998 is deemed for the purpose of subsection 247(4) of the Act, as enacted by subsection (2), to have been so made, obtained or provided on a timely basis.
	188. (1) The definitions ``foreign resource property'' and ``net capital loss'' in subsection 248(1) of the Act are replaced by the following
``foreign resource property'' « avoir minier étranger »	``foreign resource property'' has the meaning assigned by subsection 66(15), and a foreign resource property in respect of a country means a foreign resource property that is
	(a) a right, licence or privilege to explore for, drill for or take petroleum, natural gas or related hydrocarbons in that country,