Income Tax Act — I-3.3 248
olution, liquidation or winding-up of the corporation (in this definition referred to as the “liquidation entitlement”) is, by way of formula or otherwise (i) fixed, (ii) limited to a maximum, or (iii) established to be not less than a minimum, but does not include a share that is at the particular time a prescribed share, a term preferred share, a share described in paragraph (e) of the definition term preferred share in this subsection during the applicable time period referred to in that paragraph or a taxable preferred share and, for the purposes of this definition, (c) the dividend entitlement of a share of the capital stock of a corporation shall be deemed not to be fixed, limited to a maximum or established to be not less than a minimum where all dividends on the share are determined solely by reference to the dividend entitlement of another share of the capital stock of the corporation or of another corporation that controls the corporation that would not be a taxable preferred share if (i) the definition taxable preferred share in this subsection were read without reference to paragraph (f) of that definition, (ii) the other share were issued after June 18, 1987, and (iii) the other share were not a grandfathered share, a prescribed share or a share described in paragraph (e) of the definition term preferred share in this subsection, (d) the liquidation entitlement of a share of the capital stock of a corporation shall be deemed not to be fixed, limited to a maximum or established to be not less than a minimum where all the liquidation entitlement is determinable solely by reference to the liquidation entitlement of another share of the capital stock of the corporation or of another corporation that controls the corporation that would not be a taxable preferred share if (i) the definition taxable preferred share in this subsection were read without reference to paragraph (f) of that definition, (ii) the other share were issued after June 18, 1987, and (iii) the other share were not a grandfathered share, a prescribed share or a share described in paragraph (e) of the definition term preferred share in this subsection, and (e) where (i) it may reasonably be considered that the dividends that may be declared or paid to a shareholder at any time on a share (other than a prescribed share or a share described in paragraph (e) of the definition term preferred share in this subsection during the applicable time period referred to in that paragraph) of the capital stock of a corporation issued after December 15, 1987 or acquired after June 15, 1988 are derived primarily from dividends received on taxable RFI shares of the capital stock of another corporation, and (ii) it may reasonably be considered that the share was issued or acquired as part of a transaction or event or series of transactions or events one of the main purposes of which was to avoid or limit the application of Part IV.1, the share shall be deemed at that time to be a taxable RFI share; ( action particulière à une institution financière ) tax-indifferent investor [Repealed, 2026, c. 3, s. 94] taxpayer includes any person whether or not liable to pay tax; ( contribuables ) tax shelter has the meaning assigned by subsection 237.1(1); ( abri fiscal ) tax treaty with a country at any time means a comprehensive agreement or convention for the elimination of double taxation on income, between the Government of Canada and the government of the country, which has the force of law in Canada at that time; ( traité fiscal ) 10/8 policy means a life insurance policy (other than an annuity) where (a) an amount is or may become (i) payable, under the terms of a borrowing, to a person or partnership that has been assigned an interest in the policy or in an investment account in respect of the policy, or (ii) payable (within the meaning assigned by the definition amount payable in subsection 138(12)) under a policy loan (as defined in subsection 148(9)) made in accordance w