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for the purpose of determining the income of the transferor and the transferee for their taxation years following their taxation years referred to in paragraph 138(11.5)(h), amounts included under paragraphs 138(4)(b) and 12(1)(e.1) in computing the transferor’s income for its taxation year referred to in paragraph 138(11.5)(h) in respect of the insurance policies of the business referred to in paragraph 138(11.5)(a) are deemed to have been included in computing the income of the transferee, and not of the transferor, for their taxation years referred to in paragraph 138(11.5)(h),