Income Tax Act — I-3.3 132.2
nsideration for the disposition of the property, at the transfer time; (b) subject to paragraph (l), the last taxation years of the funds that began before the transfer time are deemed to have ended at the acquisition time, and their first post-exchange years are deemed to have begun immediately after those last taxation years ended; (c) each depreciable property of a fund (other than property to which subsection (5) applies and property to which paragraph (d) would, if this Act were read without reference to this paragraph, apply) is deemed to have been disposed of, and to have been reacquired, by the fund at the second intervening time for an amount equal to the lesser of (i) the fair market value of the property at the depreciables disposition time, and (ii) the greater of (A) the lesser of its capital cost and its cost amount to the disposing fund at the depreciables disposition time, and (B) the amount that the fund designates in respect of the property in a notification to the Minister accompanying the election in respect of the qualifying exchange; (d) if at the second intervening time the undepreciated capital cost to a fund of depreciable property of a prescribed class exceeds the fair market value of all the property of that class, the excess is to be deducted in computing the fund’s income for the taxation year that includes the transfer time and is deemed to have been allowed in respect of property of that class under regulations made for the purpose of paragraph 20(1)(a); (e) except as provided in paragraph (m), the transferor’s cost of any particular property received by the transferor from a transferee as consideration for the disposition of the property is deemed to be (i) nil, if the particular property is a unit of the transferee, and (ii) the particular property’s fair market value at the transfer time, in any other case; (f) the transferor’s proceeds of disposition of any units of a transferee that were disposed of by the transferor at any particular time that is within 60 days after the transfer time in exchange for shares of the transferor, are deemed to be equal to the cost amount of the units to the transferor immediately before the particular time; (g) if, at any particular time that is within 60 days after the transfer time, a taxpayer disposes of shares of the transferor to the transferor in exchange for units of a transferee (i) the taxpayer’s proceeds of disposition of the shares and the cost to the taxpayer of the units are deemed to be equal to the cost amount to the taxpayer of the shares immediately before the particular time, (ii) for the purposes of applying section 116 in respect of the disposition, the shares are deemed to be excluded property of the taxpayer, (iii) where the qualifying exchange occurs after 2004, for the purposes of applying section 218.3 in respect of that exchange, the payment or crediting of the units to the taxpayer by the transferor is deemed not to be an assessable distribution, (iv) where all of the taxpayer’s shares of the transferor have been so disposed of, for the purpose of applying section 39.1 in respect of the taxpayer after that disposition, the transferee is deemed to be the same entity as the transferor, (v) for the purpose of the definition designated beneficiary in section 210, the units are deemed not to have been held at any time by the transferor, and (vi) if the taxpayer is at the particular time affiliated with the transferor or the transferee, (A) those units are deemed not to be identical to any other units of the transferee, (B) if the taxpayer is the transferee, and the units cease to exist when the taxpayer acquires them (or, for greater certainty, when the taxpayer would but for that cessation have acquired them), the taxpayer is deemed (I) to have acquired those units at the particular time, and (II) to have disposed of those units immediately after the particular time for proceeds of disposition equal to the cost amount to the taxpayer of t