Income Tax Act — I-3.3 139.1
Definitions 139.1 (1) The definitions in this subsection apply in this section and sections 139.2 and 147.4. conversion benefit means a benefit received in connection with the demutualization of an insurance corporation because of an interest, before the demutualization, of any person in an insurance policy to which the insurance corporation has been a party. ( avantage de transformation ) deadline for a payment in respect of a demutualization of an insurance corporation means the latest of (a) the end of the day that is 13 months after the time of the demutualization, (b) where the entire amount of the payment depends on the outcome of an initial public offering of shares of the corporation or a holding corporation in respect of the insurance corporation, the end of the day that is 60 days after the day on which the offering is completed, (c) where the payment is made after the initial deadline for the payment and it is reasonable to conclude that the payment was postponed beyond that initial deadline because there was not sufficient information available 60 days before that initial deadline with regard to the location of a person, the end of the day that is six months after such information becomes available, and (d) the end of any other day that is acceptable to the Minister. ( échéance ) demutualization means the conversion of an insurance corporation from a mutual company into a corporation that is not a mutual company. ( démutualisation ) holding corporation means a corporation that (a) in connection with the demutualization of an insurance corporation, has issued shares of its capital stock to stakeholders; and (b) owns shares of the capital stock of the insurance corporation acquired in connection with the demutualization that entitle it to 90% or more of the votes that could be cast in respect of shares under all circumstances at an annual meeting of (i) shareholders of the insurance corporation, or (ii) shareholders of the insurance corporation and holders of insurance policies to which the insurance corporation is a party. ( société de portefeuille ) initial deadline for a payment is the time that would, if the definition deadline were read without reference to paragraph (c) of that definition, be the deadline for the payment. ( échéance initiale ) mutual holding corporation , in respect of an insurance corporation, means a mutual company established to hold shares of the capital stock of the insurance corporation, where the only persons entitled to vote at an annual meeting of the mutual company are policyholders of the insurance corporation. ( société mutuelle de portefeuille ) ownership rights means (a) in a particular mutual holding corporation, the following rights and interests held by a person in respect of the particular corporation because of an interest or former interest of any person in an insurance policy to which an insurance corporation, in respect of which the particular corporation is the mutual holding corporation, has been a party: (i) rights that are similar to rights attached to shares of the capital stock of a corporation, and (ii) all other rights with respect to, and interests in, the particular corporation as a mutual company; and (b) in a mutual insurance corporation, the following rights and interests held by a person in respect of the mutual insurance corporation because of an interest or former interest of any person in an insurance policy to which that corporation has been a party: (i) rights that are similar to rights attached to shares of the capital stock of a corporation, (ii) all other rights with respect to, and interests in, the mutual insurance corporation as a mutual company, and (iii) any contingent or absolute right to receive a benefit in connection with the demutualization of the mutual insurance corporation. ( droits de propriété ) person includes a partnership. ( personne ) share of the capital stock of a corporation includes a right granted by the corporation to acquire