Petroleum and Gas Revenue Tax Act — P-12 6
ty. Where taxpayer member of partnership (3) For the purposes of subsection (2), where a taxpayer was a member of a partnership at the end of a fiscal period of the partnership, (a) any property acquired or disposed of by the partnership shall be deemed to have been acquired or disposed of by the taxpayer to the extent of his share thereof; (b) any property deemed by paragraph (a) to have been acquired or disposed of by the taxpayer shall be deemed to have been acquired or disposed of by him on the day the property was acquired or disposed of by the partnership; (c) if the partnership has received, or is entitled to receive, an amount referred to in paragraph (2)(j) or (k), the taxpayer shall be  deemed to have received, or to be entitled to receive, the amount to the extent of his share thereof, on the day the partnership received, or is entitled to receive, the amount; (d) any expenditure incurred or expense recovered by the partnership shall be deemed to have been incurred or recovered, as the case may be, by the taxpayer to the extent of his share thereof; (e) any expenditure or expense deemed by paragraph (d) to have been incurred or recovered, as the case may be, by the taxpayer shall be deemed to have been incurred or recovered by him on the day the expenditure was incurred or the expense was recovered by the partnership; (f) if an amount referred to in paragraph (2)(f) or (h) has become receivable by the partnership, the amount shall be deemed to have become receivable by the taxpayer, to the extent of his share thereof, on the day the amount became receivable by the partnership; (g) any amount referred to in paragraph (2)(f), (g) or (h) in respect of the partnership that is established by the partnership to have become a bad debt before a particular time shall be deemed to have become an amount referred to in that paragraph that was established by the taxpayer to have become a bad debt before the particular time to the extent of his share thereof; and (h) any amount referred to in paragraph (2)(i) received by the partnership shall be deemed to be an amount referred to in that paragraph received by the taxpayer at the time it was received by the partnership to the extent of the taxpayer’s share thereof. Proceeds of disposition of property (4) For the purposes of subsection (2), where a taxpayer disposes of a property referred to in paragraph (2)(b), his proceeds of disposition shall be deemed to be the greater of (a) his actual proceeds of disposition, and (b) the fair market value of the property. Interpretation (5) For the purposes of subsection (6), former corporation means, in respect of (a) an amalgamation of corporations, a “predecessor corporation” described in subsection 87(1) of the Income Tax Act , or (b) a winding-up of a corporation, a “subsidiary” described in subsection 88(1) of the Income Tax Act ; ( personne morale remplacée ) successor corporation means, in respect of (a) an amalgamation of corporations, a “new corporation” described in subsection 87(1) of the Income Tax Act , or (b) a winding-up of a corporation, a “parent” described in subsection 88(1) of the Income Tax Act . ( personne morale remplaçante ) Rules where amalgamation or winding-up (6) Notwithstanding subsection (4), where at a particular time after December 31, 1982 there is an amalgamation of corporations within the meaning of subsection 87(1) of the Income Tax Act or a winding-up of a corporation as described in subsection 88(1) of that Act, the following rules apply for the purposes of subsection 5(8) and this section in respect of the successor corporation after the particular time: (a) any prescribed exploration and development expense made or incurred by a former corporation shall be deemed to be a prescribed exploration and development expense made or incurred by the successor corporation at the time when the expense was made or incurred by the former corporation; (b) any prescribed enhanced recovery equipment acquired by a form