Income Tax Act — I-3.3 138
 the transfer, in the paid-up capital in respect of the particular class of shares as a result of the acquisition by the corporation of the transferred property; and (b) in computing the paid-up capital, at any time after December 15, 1987, in respect of any particular class of shares of the capital stock of the qualified related corporation, there shall be added an amount equal to the lesser of (i) the amount, if any, by which (A) the total of all amounts each of which is an amount deemed by subsection 84(3), 84(4) or 84(4.1) to be a dividend on shares of that class paid after December 15, 1987 and before that time by the corporation exceeds (B) the total of such dividends that would have been determined under clause 138(11.7)(b)(i)(A) if this Act were read without reference to paragraph 138(11.7)(a), and (ii) the total of all amounts each of which is an amount required by paragraph 138(11.7)(a) to be deducted in computing the paid-up capital in respect of that class of shares after December 15, 1987 and before that time. Rules on transfers of depreciable property (11.8) Where (a) subsection 138(11.5) is applicable in respect of a transfer of depreciable property by a non-resident insurer to a qualified related corporation, (b) the provisions of subsection 85(1) were not required to be applied in respect of the transfer, and (c) the capital cost to the insurer of the depreciable property exceeds its proceeds of disposition therefor, for the purposes of sections 13 and 20 and any regulations made under paragraph 20(1)(a), the following rules apply: (d) the capital cost of the depreciable property to the corporation shall be deemed to be the amount that was the capital cost thereof to the insurer, and (e) the excess shall be deemed to have been allowed to the corporation in respect of the property under regulations made under paragraph 20(1)(a) in computing its income for taxation years ending before the transfer. Computation of contributed surplus (11.9) Where, after December 15, 1987, subsection 138(11.5) or 85(1) is applicable in respect of a transfer of property by a person or partnership to an insurance corporation resident in Canada and (a) the total of (i) the fair market value, immediately after the transfer, of any consideration (other than shares of the capital stock of the corporation) received or receivable by the person or partnership from the corporation for the transferred property, (ii) the increase, if any, in the paid-up capital of all the shares of the capital stock of the corporation (determined without reference to subsection 138(11.7) or 85(2.1) as it applies in respect of the transfer) arising on the transfer, and (iii) the increase, if any, in the contributed surplus of the corporation (determined without reference to this subsection as it applies in respect of the transfer) arising on the transfer exceeds (b) the total of (i) the total of all amounts each of which is an amount required to be deducted in computing the paid-up capital of a class of shares of the capital stock of the corporation under subsection 138(11.7) or 85(2.1), as the case may be, as it applies in respect of the transfer, and (ii) the cost to the corporation of the transferred property, for the purposes of paragraph 84(1)(c.1) and subsections 219(5.2) and 219(5.3), the contributed surplus of the corporation arising on the transfer shall be deemed to be the amount, if any, by which the amount of the contributed surplus otherwise determined exceeds the amount, if any, by which the total determined under paragraph 138(11.9)(a) exceeds the total determined under paragraph 138(11.9)(b). Computation of income of non-resident insurer (11.91) Where, at any time in a particular taxation year, (a) a non-resident insurer carries on an insurance business in Canada, and (b) immediately before that time, the insurer was not carrying on an insurance business in Canada or ceased to be exempt from tax under this Part on any income from such business