Income Tax Act — I-3.3 53
132.1(2) to be added in computing the adjusted cost base to the taxpayer of the unit; (d.3) where the property is a share of the capital stock of a corporation of which the taxpayer was, at any time, a specified shareholder, any expense incurred by the taxpayer in respect of land or a building of the corporation that was by reason of subsection 18(2) or 18(3.1) not deductible by the taxpayer in computing the taxpayer’s income for any taxation year commencing before that time; (e) where the property is an interest in a partnership, (i) an amount in respect of each fiscal period of the partnership ending after 1971 and before that time, equal to the total of all amounts each of which is the taxpayer’s share (other than a share under an agreement referred to in subsection 96(1.1)) of the income of the partnership from any source for that fiscal period, computed as if this Act were read without reference to (A) paragraphs 38(a.1) to (a.3) and the fractions set out in the formula in paragraph 14(1)(b) and in subsection 14(5), paragraph 38(a) and subsection 41(1), (A.1) subparagraph 39(1)(a)(i.1) in respect of an object referred to in that subparagraph that is not the subject of a gifting arrangement, as defined in subsection 237.1(1), nor a property that is a tax shelter, (A.2) the description of C in the formula in paragraph 14(1)(b), and (B) paragraph (i), paragraphs 12(1)(o) and (z.5), 18(1)(m), 20(1)(v.1) and 29(1)(b) and (2)(b), section 55, subsections 69(6) and (7) and paragraph 82(1)(b) of this Act and paragraphs 20(1)(gg) and 81(1)(r) and (s) of the Income Tax Act , chapter 148 of the Revised Statutes of Canada, 1952, and the provisions of the Income Tax Application Rules relating to income from the operation of new mines, (ii) the taxpayer’s share of any capital dividends and any life insurance capital dividends received by the partnership before that time on shares of the capital stock of a corporation that were partnership property, (iii) the taxpayer’s share of the amount, if any, by which (A) any proceeds of a life insurance policy received by the partnership after 1971 and before that time in consequence of the death of any person whose life was insured under the policy, exceeds the total of all amounts each of which is (B) the adjusted cost basis (in this subparagraph as defined in subsection 148(9)), immediately before the death, of (I) if the death occurs before March 22, 2016, the policy to the partnership, and (II) if the death occurs after March 21, 2016, a policyholder’s interest in the policy, (C) the amount by which the fair market value of consideration given in respect of a disposition of an interest in the policy exceeds the greater of the amount determined under subparagraph 148(7)(a)(i) in respect of the disposition and the adjusted cost basis to the policyholder of the interest immediately before the disposition, if (I) the death occurs after March 21, 2016, and (II) the disposition was by a policyholder (other than a taxable Canadian corporation) after 1999 and before March 22, 2016, or (D) if the death occurs after March 21, 2016, an interest in the policy was disposed of by a policyholder (other than a taxable Canadian corporation) after 1999 and before March 22, 2016 and subsection 148(7) applied to the disposition, the amount, if any, determined by the formula A − B where A is the amount, if any, by which the lesser of the adjusted cost basis to the policyholder of the interest immediately before the disposition and the fair market value of consideration given in respect of the disposition exceeds the amount determined under subparagraph 148(7)(a)(i) in respect of the disposition, and B is the absolute value of the negative amount, if any, that would be, in the absence of section 257, the adjusted cost basis, immediately before the death, of the interest in the policy, (iv) where the taxpayer has, after 1971, made a contribution of capital to the partnership otherwise than by way of loan, such part