(c) the amount is transferred directly to another registered pension plan to be held in connection with a money purchase provision (in this subsection referred to as the ``current provision'') of the other plan;

    (d) the amount is transferred in conjunction with the transfer of amounts from the former provision to the current provision on behalf of all or a significant number of members of the transferor plan whose benefits under the former provision are replaced by benefits under the current provision; and

    (e) the transfer is acceptable to the Minister and the Minister has so notified the administrator of the transferor plan in writing.

(3) Paragraphs 147.3(8)(b) and (c) of the Act are replaced by the following:

    (b) the amount is transferred in respect of the actuarial surplus under a defined benefit provision of the transferor plan;

    (c) the amount is transferred directly to another registered pension plan to be held in connection with a money purchase provision of the other plan;

(4) Subsection (1) applies to transfers that occur after November 1999.

(5) Subsection (2) applies to transfers that occur after 1998.

(6) Subsection (3) applies to transfers that occur after 1990.

145. (1) Paragraphs 149(1)(d) to (d.2) of the Act are replaced by the following:

Corporations owned by the Crown

    (d) a corporation, commission or association all of the shares (except directors' qualifying shares) or of the capital of which was owned by one or more persons each of which is Her Majesty in right of Canada or Her Majesty in right of a province;

Corporations 90% owned by the Crown

    (d.1) a corporation, commission or association not less than 90% of the shares (except directors' qualifying shares) or of the capital of which was owned by one or more persons each of which is Her Majesty in right of Canada or Her Majesty in right of a province;

Wholly-owne d corporations

    (d.2) a corporation all of the shares (except directors' qualifying shares) or of the capital of which was owned by one or more persons each of which is a corporation, commission or association to which this paragraph or paragraph (d) applies for the period;

(2) Subparagraph 149(1)(d.3)(i) of the Act is replaced by the following:

      (i) one or more persons each of which is Her Majesty in right of Canada or a province or a person to which paragraph (d) or (d.2) applies for the period, or

(3) Paragraph 149(1)(d.4) of the Act is replaced by the following:

Combined ownership

    (d.4) a corporation all of the shares (except directors' qualifying shares) or of the capital of which was owned by one or more persons each of which is a corporation, commission or association to which this paragraph or any of paragraphs (d) to (d.3) applies for the period;

(4) The portion of paragraph 149(1)(d.6) of the Act before subparagraph (i) is replaced by the following:

Subsidiaries of municipal corporations

    (d.6) subject to subsections (1.2) and (1.3), a particular corporation all of the shares (except directors' qualifying shares) or of the capital of which was owned by one or more persons each of which is a corporation, commission or association to which paragraph (d.5) or this paragraph applies for the period if the income for the period of the particular corporation from activities carried on outside

(5) Clause 149(1)(o.2)(ii)(A) of the Act is replaced by the following:

        (A) limited its activities to

          (I) acquiring, holding, maintaining, improving, leasing or managing capital property that is real property or an interest in real property owned by the corporation, another corporation described by this subparagraph and subparagraph (iv) or a registered pension plan, and

          (II) investing its funds in a partnership that limits its activities to acquiring, holding, maintaining, improving, leasing or managing capital property that is real property or an interest in real property owned by the partnership,

(6) Subsection 149(1.1) of the Act is replaced by the following:

Exception

(1.1) Where at a particular time

    (a) a corporation, commission or association (in this subsection referred to as ``the entity'') would, but for this subsection, be described in any of paragraphs (1)(d) to (d.6),

    (b) one or more other persons (other than Her Majesty in right of Canada or a province, a municipality in Canada or a person which, at the particular time, is a person described in any of subparagraphs (1)(d) to (d.6)) have at the particular time one or more rights in equity or otherwise, either immediately or in the future and either absolutely or contingently to, or to acquire, shares or capital of the entity, and

    (c) the exercise of the rights referred to in paragraph (b) would result in the entity not being a person described in any of paragraphs (1)(d.1) to (d.6) at the particular time,

the entity is deemed not to be, at the particular time, a person described in any of paragraphs (1)(d) to (d.6).

Election

(1.11) Subsection (1) does not apply in respect of a person's taxable income for a particular taxation year that begins after 1998 where

    (a) paragraph (1)(d) did not apply in respect of the person's taxable income for the person's last taxation year that began before 1999;

    (b) paragraph (1)(d.2), (d.3) or (d.4) would, but for this subsection, have applied in respect of the person's taxable income for the person's first taxation year that began after 1998;

    (c) there has been no change in the direct or indirect control of the person during the period that

      (i) began at the beginning of the person's first taxation year that began after 1998, and

      (ii) ends at the end of the particular year;

    (d) the person elects in writing before 2002 that this subsection apply; and

    (e) the person has not notified the Minister in writing before the particular year that the election has been revoked.

(7) Subsection 149(1.2) of the Act is replaced by the following:

Income test

(1.2) For the purposes of paragraphs (1)(d.5) and (d.6), income of a corporation, commission or association from activities carried on outside the geographical boundaries of a municipality does not include income from activities carried on

    (a) under an agreement in writing between

      (i) the corporation, commission or association, and

      (ii) a person who is Her Majesty in right of Canada or a province or a municipality or corporation to which any of paragraphs (1)(d) to (d.6) applies and that is controlled by Her Majesty in right of Canada or a province or by a municipality in Canada

    within the geographical boundaries of,

      (iii) where the person is Her Majesty in right of Canada or a corporation controlled by Her Majesty in right of Canada, Canada,

      (iv) where the person is Her Majesty in right of a province or a corporation controlled by Her Majesty in right of a province, the province, and

      (v) where the person is a municipality in Canada or a corporation controlled by a municipality in Canada, the municipality; or

    (b) in a province as

      (i) a producer of electrical energy or natural gas, or

      (ii) a distributor of electrical energy, heat, natural gas or water,

    where the activities are regulated under the laws of the province.

(8) Subsections (1) to (4), (6) and (7) apply to taxation years and fiscal periods that begin after 1998 except that,

    (a) where a corporation, commission or association so elects in writing and files the election with the Minister of National Revenue on or before the day that is six months after the end of the month in which this Act receives royal assent, the reference to ``at a particular time'' in subsection 149(1.1) of the Act, as enacted by subsection (6), shall be read as a reference to ``at any time after November 1999''; and

    (b) an election referred to in subsection 149(1.11) of Act, as enacted by subsection (6), filed with the Minister of National Revenue on or before the day that is six months after the end of the month in which this Act receives royal assent, is deemed to have been filed in accordance with that subsection of the Act.

(9) Subsection (5) applies to taxation years that end after 2000.

146. The portion of subsection 149.1(6.4) of the Act after paragraph (d) is replaced by the following:

applies in prescribed form to the Minister of National Revenue for registration, that Minister may register the organization for the purposes of this Act and, where the organization so applies or is so registered, this section, paragraph 38(a.1), sections 110.1, 118.1, 168, 172, 180 and 230, subsection 241(3.2) and Part V apply, with such modifications as the circumstances require, to the organization as if it were an applicant for registration as a charitable organization or as if it were a registered charity that is designated as a charitable organization, as the case may be.

147. (1) Clause 150(1)(a)(i)(B) of the Act is replaced by the following:

        (B) carries on business in Canada, unless the corporation's only revenue from carrying on business in Canada in the year consists of amounts in respect of which tax was payable by the corporation under subsection 212(5.1),

(2) Subsection (1) applies to the 2001 and subsequent taxation years.

148. (1) Subsection 150.1(5) of the Act is replaced by the following:

Application to other Parts

(5) This section also applies to Parts I.2 to XIII, with such modifications as the circumstances require.

(2) Subsection (1) applies to the 2001 and subsequent taxation years.

149. (1) Paragraph 152(4)(b) of the Act is amended by adding the following after subparagraph (iii):

      (iii.1) is made, if the taxpayer is non-resident and carries on a business in Canada, as a consequence of

        (A) an allocation by the taxpayer of revenues or expenses as amounts in respect of the Canadian business (other than revenues and expenses that relate solely to the Canadian business, that are recorded in the books of account of the Canadian business, and the documentation in support of which is kept in Canada), or

        (B) a notional transaction between the taxpayer and its Canadian business, where the transaction is recognized for the purposes of the computation of an amount under this Act or an applicable tax treaty.

(2) Paragraph 152(6)(c.1) of the Act is replaced by the following:

    (c.1) a deduction under section 119 in respect of a disposition in a subsequent taxation year,

(3) Subsection 152(6) of the Act is amended by adding the following after paragraph (f):

    (f.1) a deduction under subsection 126(2) in respect of an unused foreign tax credit (within the meaning assigned by subsection 126(7)), or under subsection 126(2.21) or (2.22) in respect of foreign taxes paid, for a subsequent taxation year,

    (f.2) a deduction under subsection 128.1(8) as a result of a disposition in a subsequent taxation year,

(4) Section 152 of the Act is amended by adding the following after subsection (6):

Reassessment where amount included in income under subsection 91(1) is reduced

(6.1) Where

    (a) a taxpayer has filed for a particular taxation year the return of income required by section 150,

    (b) the amount included in computing the taxpayer's income for the particular year under subsection 91(1) is subsequently reduced because of a reduction in the foreign accrual property income of a foreign affiliate of the taxpayer for a taxation year of the affiliate that ends in the particular year and is

      (i) attributable to the amount prescribed to be the deductible loss of the affiliate for the year that arose in a subsequent year of the affiliate that ends in a subsequent taxation year of the taxpayer, and

      (ii) included in the description of F of the definition ``foreign accrual property income'' in subsection 95(1) in respect of the affiliate for the year, and

    (c) the taxpayer has filed with the Minister, on or before the filing-due-date for the taxpayer's subsequent taxation year, a prescribed form amending the return,

the Minister shall reassess the taxpayer's tax for any relevant taxation year (other than a taxation year preceding the particular taxation year) in order to take into account the reduction in the amount included under subsection 91(1) in computing the income of the taxpayer for the year.

(5) Section 152 of the Act is amended by adding the following after subsection (9):

Where tax deemed not to be assessed

(10) Notwithstanding any other provision of this section, an amount of tax for which adequate security is accepted by the Minister under subsection 220(4.5) or (4.6) is, until the end of the period during which the security is accepted by the Minister, deemed for the purpose of any agreement entered into by or on behalf of the Government of Canada under section 7 of the Federal-Provincial Fiscal Arrangements Act not to have been assessed under this Act.

(6) Subsection (1) applies to the 2000 and subsequent taxation years.

(7) Subsections (2), (3) and (5) apply to taxation years that end after October 1, 1996.

(8) In respect of

    (a) a deduction under section 119 of the Act, as enacted by subsection 102(2), or an adjustment under subsection 128.1(8) of the Act, as enacted by subsection 123(5), in respect of a disposition by a taxpayer, or

    (b) a deduction under subsection 126(2.21) or (2.22) of the Act, as enacted by subsection 117(6), in respect of foreign taxes paid by a taxpayer,

the taxpayer is deemed to have filed the prescribed form described in subsection 152(6) of the Act in a timely manner if the taxpayer files the form with the Minister of National Revenue on or before the later of the day on or before which the taxpayer would, but for this subsection, be required to file the form and the taxpayer's filing-due date for the taxation year that includes the day on which this Act receives royal assent.

(9) Subsection (4) applies to taxation years of foreign affiliates that begin after November 1999.

150. (1) Subsection (2) applies in respect of an individual if, at any particular time after October 1, 1996 and before the day that is two years before the day on which this Act receives royal assent,

    (a) the individual ceased to be resident in Canada; or

    (b) where the individual is a trust, the trust made a distribution of property to which subsection 107(2) of the Act does not apply solely because of the application of subsection 107(5) of the Act, as enacted by subsection 80(18).