Income Tax Act — I-3.3 149.1
f the issued shares of which are held by the foundation; ( placement non admissible ) original corporate holdings percentage of a private foundation, in respect of a class of shares of the capital stock of a corporation, means the total corporate holdings percentage of the private foundation, in respect of that class, held on March 18, 2007; ( pourcentage de participation initiale ) political activity [Repealed, 2018, c. 27, s. 17] private foundation means a charitable foundation that is not a public foundation; ( fondation privée ) promoter has the meaning assigned by section 237.1; ( promoteur ) public foundation , at a particular time, means a charitable foundation (a) more than 50% of the directors, trustees, officers or like officials of which deal at arm’s length with each other and with (i) each of the other directors, trustees, officers and like officials of the foundation, (ii) each person described by subparagraph (b)(i) or (ii), and (iii) each member of a group of persons (other than Her Majesty in right of Canada or of a province, a municipality, another registered charity that is not a private foundation, and any club, society or association described in paragraph 149(1)(l)) who do not deal with each other at arm’s length, if the group would, if it were a person, be a person described by subparagraph (b)(i), and (b) that is not, at the particular time, and would not at the particular time be, if the foundation were a corporation, controlled directly or indirectly in any manner whatever (i) by a person (other than Her Majesty in right of Canada or of a province, a municipality, another registered charity that is not a private foundation, and any club, society or association described in paragraph 149(1)(l)), (A) who immediately after the particular time, has contributed to the foundation amounts that are, in total, greater than 50% of the capital of the foundation immediately after the particular time, and (B) who immediately after the person’s last contribution at or before the particular time, had contributed to the foundation amounts that were, in total, greater than 50% of the capital of the foundation immediately after the making of that last contribution, or (ii) by a person, or by a group of persons that do not deal at arm’s length with each other, if the person or any member of the group does not deal at arm’s length with a person described in subparagraph (i); ( fondation publique ) qualified donee , at any time, means a person that is (a) registered by the Minister and that is (i) a housing corporation resident in Canada and exempt from tax under this Part because of paragraph 149(1)(i) that has applied for registration, (ii) a municipality in Canada, (iii) a municipal or public body performing a function of government in Canada that has applied for registration, (iv) a university outside Canada, the student body of which ordinarily includes students from Canada, that has applied for registration, or (v) a foreign charity that has applied to the Minister for registration under subsection (26), (b) a registered charity, (b.1) a registered journalism organization, (c) a registered Canadian amateur athletic association, or (d) Her Majesty in right of Canada or a province, the United Nations or an agency of the United Nations; ( donataire reconnu ) qualifying disbursement means a disbursement by a charity, by way of a gift or by otherwise making resources available, (a) subject to subsection (6.001), to a qualified donee, or (b) to a grantee organization, if (i) the disbursement is in furtherance of a charitable purpose (determined without reference to the definition charitable purposes in this subsection) of the charity, (ii) the charity ensures that the disbursement is exclusively applied to charitable activities in furtherance of a charitable purpose of the charity, and (iii) the charity maintains documentation sufficient to demonstrate (A) the purpose for which the disbursement is made, and (B) that the d