Income Tax Act — I-3.3 248
all circumstances (including the rate of interest on any debt or the dividend provided on any term preferred share), that (i) but for the existence at any time of the debt or the term preferred share, the particular share would not have been issued or its terms or conditions modified, and (ii) one of the main purposes for the issue of the particular share or for the modification of its terms or conditions was to avoid a limitation provided by subsection 112(2.1) or 138(6) in respect of a deduction or to avoid or limit the application of subsection 258(3), the particular share shall be deemed after December 31, 1982 to be a term preferred share of the corporation; ( action privilégiée à terme ) testamentary trust has the meaning assigned by subsection 108(1); ( fiducie testamentaire ) TFSA , being a tax-free savings account, has the meaning assigned by subsection 146.2(5); ( compte d’épargne libre d’impôt ) timber resource property has the meaning assigned by subsection 13(21); ( avoir forestier ) total pension adjustment reversal of a taxpayer for a calendar year has the meaning assigned by regulation; ( facteur d’équivalence rectifié total ) transferred capacity has the same meaning as in subsection 18.2(1); ( capacité transférée ) transmission equipment has the same meaning as in subsection 1104(13) of the Income Tax Regulations ; ( matériel de transmission ) Treasury Board means the Treasury Board established by section 5 of the Financial Administration Act ; ( Conseil du Trésor ) treaty-protected business of a taxpayer at any time means a business in respect of which any income of the taxpayer for a period that includes that time would, because of a tax treaty with another country, be exempt from tax under Part I; ( entreprise protégée par traité ) treaty-protected property of a taxpayer at any time means property any income or gain from the disposition of which by the taxpayer at that time would, because of a tax treaty with another country, be exempt from tax under Part I; ( bien protégé par traité ) trust has the meaning assigned by subsection 104(1) and, unless the context otherwise requires, includes an estate; ( fiducie ) trust account number means the number (other than a business number) (a) used by the Minister to identify a trust, and (b) of which the Minister has notified the trust; ( numéro de compte en fiducie ) undepreciated capital cost to a taxpayer of depreciable property of a prescribed class has the meaning assigned by subsection 13(21); ( fraction non amortie du coût en capital ) unit trust has the meaning assigned by subsection 108(2); ( fiducie d’investissement à participation unitaire ) unused RRSP deduction room of a taxpayer at the end of a taxation year has the meaning assigned by subsection 146(1); ( déductions inutilisées au titre des REER ) unused scientific research and experimental development tax credit of a taxpayer for a taxation year has the meaning assigned by subsection 127.3(2); ( partie inutilisée du crédit d’impôt pour des activités de recherche scientifique et de développement expérimental ) unused share-purchase tax credit of a taxpayer for a taxation year has the meaning assigned by subsection 127.2(6); ( partie inutilisée du crédit d’impôt à l’achat d’actions ) worker cooperative means a corporation that, at all relevant times, satisfies the following conditions: (a) the corporation is resident in Canada, (b) the corporation was incorporated or continued by or under the provisions of a law, of Canada or of a province, that provide for the establishment of the corporation as a cooperative corporation or that provide for the establishment of cooperative corporations, (c) the corporation is established for the purpose of providing employment to its members, (d) the corporation would be controlled by a particular person if each membership share of the capital stock of the corporation that is owned by a qualifying cooperative worker were owned by the particular person, (e) at least 75