GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Global Minimum Tax Act — G-3.3 (a)
passive income means income that is included in computing a constituent entity’s GloBE income or loss and that is (a) a dividend or dividend equivalent; (b) interest or an interest equivalent; (c) rent; (d) a royalty; (e) an annuity; or (f) a net gain from property of a type that produces income described in any of paragraphs (a) to (e). ( revenu passif )
Global Minimum Tax Act — G-3.3
patronage dividend means a distribution by a cooperative to its members. ( ristourne )
Global Minimum Tax Act — G-3.3 (a)
pension fund means (a) an entity that is established and operated in a jurisdiction exclusively or almost exclusively to administer or provide retirement benefits and ancillary or incidental benefits to individuals, if (i) the entity is regulated as such by that jurisdiction or one of its political subdivisions or local authorities, or (ii) those benefits are secured or otherwise protected by national regulations and funded by a pool of assets held through a fiduciary arrangement or trust to secure the fulfilment of the corresponding pension obligations against a case of insolvency of the entity or the MNE group of which the entity is a member; or (b) a pension services entity. ( fonds de pension )
Global Minimum Tax Act — G-3.3 (a)
pension services entity means an entity that is established and operated exclusively or almost exclusively (a) to invest funds for the benefit of entities described in paragraph (a) of the definition pension fund in this subsection; or (b) to carry out activities that are ancillary to the regulated activities carried out by an entity described in that paragraph that is a member of the same group. ( entité de services de fonds de pension )
Global Minimum Tax Act — G-3.3 (a)
permanent establishment means a place of business, including a deemed place of business, (a) that is situated in a jurisdiction and treated as a permanent establishment in accordance with an applicable tax treaty in force, provided that the jurisdiction taxes the income attributable to it in accordance with a provision similar to Article 7 of the OECD Model Tax Convention; (b) if there is no applicable tax treaty in force, in respect of which a jurisdiction taxes the income attributable to that place of business under its domestic law on a net basis similar to the manner in which it taxes its own tax residents; (c) if a jurisdiction has no corporate income tax system, that is situated in that jurisdiction and that would be treated as a permanent establishment in accordance with the OECD Model Tax Convention, provided that the jurisdiction would have had the right to tax the income attributable to it in accordance with Article 7 of that model convention; or (d) that is not already described in paragraphs (a) to (c) and through which operations are conducted outside the jurisdiction where the entity that would be the main entity, if the place of business were a permanent establishment, is located, provided that that jurisdiction exempts the income attributable to the operations conducted through the place of business. ( établissement stable )
Global Minimum Tax Act — G-3.3
person includes a corporation, partnership or trust. ( personne )
Global Minimum Tax Act — G-3.3
portfolio holding , at any time in a fiscal year, means ownership interests in an entity that are held at that time by a constituent entity, either alone or together with other group entities, and that carry rights to less than 10% of the profits, capital, reserves or voting rights of that entity. ( titres de portefeuille )
Global Minimum Tax Act — G-3.3 (a)
prescribed means (a) in the case of a form, the information to be given on a form or the manner of filing a form, authorized by the Minister; (b) in the case of the manner of making or filing an election, authorized by the Minister; and (c) in any other case, prescribed by regulation or determined in accordance with rules prescribed by regulation. ( prescrit )
Global Minimum Tax Act — G-3.3 (a)
QDMTT transition year , of an MNE group in respect of a jurisdiction, means the first fiscal year in which (a) a constituent entity of, or joint venture entity in respect of, the MNE group that is located in the jurisdiction is subject to a qualified domestic minimum top-up tax; and (b) subsection 33 (1), 47 (2) or 53 (3), section 45 or an equivalent provision under the laws of the jurisdiction does not apply for the jurisdiction. ( année de transition ICMNA )
Global Minimum Tax Act — G-3.3
qualified ancillary international shipping income has the same meaning as in subsection 19 (7). ( revenu de transport maritime international accessoire admissible )
Global Minimum Tax Act — G-3.3 (a)
qualified debt release amount , for a fiscal year, of a constituent entity that is a debtor, means an amount in respect of a debt release to the extent that (a) the debt release is pursuant to a statutory insolvency or bankruptcy proceeding (i) that is supervised by a court or other judicial body in the jurisdiction in which the debtor is located, or (ii) under which an independent insolvency administrator is appointed; (b) the following conditions are met: (i) the debt release arises pursuant to an arrangement with one or more creditors that are not connected with the debtor (each referred to in this definition as a “third-party creditor”), (ii) it is reasonable to consider that, in the absence of the release of debts owed to one or more third-party creditors under the arrangement, the debtor would be insolvent within 12 months of the date of the release, and (iii) the debtor provides an independent expert opinion attesting that the condition in subparagraph (ii) is met; or (c) if neither paragraph (a) nor (b) applies, (i) the amount is in respect of a debt owed to a third-party creditor, (ii) the debtor’s liabilities exceed the fair market value of its assets, determined immediately before the debt release, and (iii) the amount does not exceed the least of (A) if, as a result of the debt release, the debtor’s assets are greater than or equal to its liabilities, the debtor’s liabilities less the fair market value of its assets, determined immediately before the debt release, (B) if any amount included, as a result of the debt release, in computing net income or loss is offset by a corresponding reduction in deferred tax assets, the reduction in the debtor’s deferred tax assets resulting from the debt release, and (C) the amount included, as a result of the debt release, in computing net income or loss. ( montant de la libération de la dette admissible )
Global Minimum Tax Act — G-3.3
qualified domestic minimum top-up tax , for a fiscal year, means a law of a jurisdiction that has the status of a qualified domestic minimum top-up tax (including transitional qualified status) for the fiscal year as determined by the Inclusive Framework and published on the OECD’s website. ( impôt complémentaire minimum national admissible )
Global Minimum Tax Act — G-3.3
qualified flow-through ownership interest has the same meaning as in subsection 28 (1). ( titre de participation intermédiaire admissible )
Global Minimum Tax Act — G-3.3
qualified IIR , for a fiscal year, means an IIR that has qualified status (including transitional qualified status) for the fiscal year as determined by the Inclusive Framework and published on the OECD’s website. ( RDIR admissible )
Global Minimum Tax Act — G-3.3 (a)
qualified imputation tax means an amount of covered taxes, paid or accrued by a constituent entity, that is (a) imposed under the laws of a jurisdiction (referred to in this definition as the “subject jurisdiction”); and (b) refundable to, or creditable against the tax liability of, the beneficial owner of a dividend or similar distribution by the constituent entity (or by the main entity in respect of the constituent entity, if the constituent entity is a permanent establishment), if (i) the amount is refundable or creditable under (A) subsection 126(1) or (2) of the Income Tax Act , or (B) a provision of the laws of another jurisdiction that is substantially similar to one of those subsections, or (ii) the beneficial owner is (A) subject to tax on a current basis, in respect of the dividend or similar distribution, under the laws of the subject jurisdiction at a nominal rate that is greater than or equal to the minimum rate, (B) an individual who is (I) resident for income tax purposes in the subject jurisdiction, and (II) subject to tax, in respect of the dividend or similar distribution as ordinary income, under the laws of the subject jurisdiction, (C) a governmental entity or international organization, (D) an investment entity (other than a group entity in respect of the constituent entity) that is created and regulated in the subject jurisdiction, (E) a non-profit organization or pension fund that is created and managed in the subject jurisdiction, or (F) a life insurance company that is located in the subject jurisdiction to the extent that the dividend or similar distribution is (I) received in connection with a business that is substantially similar to that of a pension fund, and (II) subject to tax, under the laws of the subject jurisdiction, in a manner that is substantially similar to the manner in which a pension fund is, under the laws of the subject jurisdiction, subject to tax in respect of a dividend or similar distribution. ( impôt d’imputation admissible )
Global Minimum Tax Act — G-3.3
qualified refundable tax credit means a refundable tax credit (other than any amount of tax creditable or refundable pursuant to a qualified imputation tax or a disqualified refundable imputation tax) to the extent that it is designed to be payable or available as cash or cash equivalents within four years from when a constituent entity satisfies the conditions for receiving the credit under the laws of the jurisdiction granting the credit. ( crédit d’impôt remboursable admissible )
Global Minimum Tax Act — G-3.3
qualified UTPR , for a fiscal year, means a UTPR that has qualified status (including transitional qualified status) for the fiscal year as determined by the Inclusive Framework and published on the OECD’s website. ( RPII admissible )
Global Minimum Tax Act — G-3.3
qualifying MNE group has the same meaning as in subsection 9 (1). ( groupe d’EMN admissible )
Global Minimum Tax Act — G-3.3 (a)
qualifying non-profit subsidiary , for a fiscal year, means an entity in respect of an MNE group if (a) the entity is wholly owned by one or more entities that are non-profit organizations; and (b) the revenue of the MNE group for the fiscal year, determined without reference to the revenues of any group entities that are non-profit organizations and of any group entities that would, in the absence of this definition, be described in paragraph 13 (1)(b) or (c), is less than (i) the revenue threshold of the MNE group for the fiscal year, and (ii) 25% of the revenue of the MNE group for the fiscal year. ( filiale à but non lucratif admissible )
Global Minimum Tax Act — G-3.3
qualifying tier one capital means an instrument issued by a constituent entity pursuant to regulatory requirements applicable to the banking or insurance sector that is convertible to equity or written down if a pre-specified trigger event occurs and that has other features that are designed to aid loss absorbency in the event of a financial crisis. ( fonds propres de catégorie 1 admissibles )
Global Minimum Tax Act — G-3.3 (a)
real estate investment vehicle means an entity (a) the taxation of which achieves a single level of taxation either in its hands or the hands of its interest holders (with at most one year of deferral); and (b) that (i) holds predominantly immovable property, and (ii) is itself widely held. ( véhicule d’investissement immobilier )
Global Minimum Tax Act — G-3.3
recapture account loss carry-forward has the same meaning as in subsection 37 (3). ( report des pertes du compte de récupération )
Global Minimum Tax Act — G-3.3 (a)
recapture exception accrual means a tax expense accrued in the financial accounts of a constituent entity that is attributable to changes in associated deferred tax liabilities in respect of (a) cost recovery allowance on a tangible asset; (b) the cost of a licence or similar arrangement from a government for the use of immovable property or the exploitation of natural resources that entails significant investment in tangible assets; (c) research and development expenses; (d) decommissioning and remediation expenses; (e) fair value accounting on unrealized net gains; (f) foreign currency exchange net gains; (g) insurance reserves and insurance policy deferred acquisition costs; (h) a gain that is (i) from the sale of tangible property located in the jurisdiction in which the constituent entity is located, and (ii) re-invested in tangible property located in the jurisdiction; and (i) an additional amount accrued as a result of accounting principle changes with respect to an item described in any of paragraphs (a) to (h). ( charge d’impôt non soumise à récupération )
Global Minimum Tax Act — G-3.3
regulation means a regulation made under this Act. ( règlement )
Global Minimum Tax Act — G-3.3
relevant parent entity has the same meaning as in subsection 14 (3). ( entité mère pertinente )
Global Minimum Tax Act — G-3.3
revenue threshold has the same meaning as in subsection 9 (2). ( seuil de chiffre d’affaires )
Global Minimum Tax Act — G-3.3 (a)
reverse hybrid entity means a flow-through entity, if (a) in relation to an owner that holds a direct ownership interest in the flow-through entity, the flow-through entity is not fiscally transparent; or (b) in relation to an owner that holds an indirect ownership interest in the flow-through entity, (i) the flow-through entity is not fiscally transparent, and (ii) each entity through which that owner holds its indirect ownership interest is fiscally transparent. ( entité hybride inversée )
Global Minimum Tax Act — G-3.3
revocation year , in respect of a five-year election or an election under section 26 , means the first fiscal year for which the election is no longer in effect because it has been revoked. ( année de révocation )
Global Minimum Tax Act — G-3.3
short-term portfolio holding , of a constituent entity that receives or accrues dividends or other distributions, at any time in a fiscal year, means a portfolio holding that has been economically held by the constituent entity for less than one year at the date of the distribution. ( titre de portefeuille à court terme )
Global Minimum Tax Act — G-3.3
standard constituent entity has the same meaning as in subsection 11 (3). ( entité constitutive type )
Global Minimum Tax Act — G-3.3 (a)
stapled structure means an arrangement entered into by the ultimate parent entities of two or more groups under which (a) not less than 50% of the ownership interests in each ultimate parent entity are (by reason of the form of ownership, restrictions on transfer or any other terms or conditions) combined with not less than 50% of the ownership interests in each other ultimate parent entity and cannot be transferred or traded other than in that combined form; (b) if the combined ownership interests of the ultimate parent entities are listed on a securities market, they are quoted at a single price; and (c) financial statements are prepared by one of the ultimate parent entities in which the assets, liabilities, income, expenses and cash flows of all the entities of all the groups are presented together as those of a single economic unit, and those financial statements (i) would be consolidated financial statements if the entities of all the groups were included in a single group and the ultimate parent entity that prepared the financial statements was the ultimate parent entity of that group, and (ii) are required by an applicable regulatory regime of a jurisdiction to be externally audited. ( structure indissociable )
Global Minimum Tax Act — G-3.3 (a)
stateless constituent entity means a constituent entity of an MNE group that is either (a) a stateless entity under paragraph 5 (2)(b); or (b) a stateless permanent establishment under paragraph 5 (3)(d). ( entité constitutive apatride )
Global Minimum Tax Act — G-3.3
substance-based income exclusion amount has the same meaning as in subsection 32 (1). ( montant de l’exclusion de revenus fondée sur la substance )
Global Minimum Tax Act — G-3.3 (a)
substitute loss carry-forward recapture amount , of a constituent entity that is located in a particular jurisdiction, means an amount if (a) the amount would be a tax loss or a portion of a tax loss (referred to in this definition as the “consumed domestic loss”) of the constituent entity if the consumed domestic loss were not offset against another amount — in respect of the income of another entity (referred to in this definition as the “controlled foreign company”) that is located in a jurisdiction other than the particular jurisdiction and in which the constituent entity holds, directly or indirectly, an ownership interest — that is included, under the controlled foreign company tax regime of the particular jurisdiction, in computing the constituent entity’s taxable income in the particular jurisdiction; and (b) the income tax laws of the particular jurisdiction allow the consumed domestic loss to be recaptured by the constituent entity in subsequent taxation years, by recharacterizing amounts of income of the constituent entity from sources in the particular jurisdiction as amounts in respect of income of the controlled foreign company that are included, under the controlled foreign company tax regime of the particular jurisdiction, in computing the constituent entity’s taxable income in the particular jurisdiction or as amounts of income from another foreign source. ( montant de récupération du report de pertes de remplacement )
Global Minimum Tax Act — G-3.3 (a)
substitute loss carry-forward tax credit , of a constituent entity that is located in a particular jurisdiction, means a tax credit, or any portion of a tax credit, of the constituent entity that (a) arises under the income tax laws of the particular jurisdiction in respect of tax paid to the government of a jurisdiction other than the particular jurisdiction by another entity (referred to in this definition as the “controlled foreign company”) that is located in a jurisdiction other than the particular jurisdiction, in which the constituent entity holds, directly or indirectly, an ownership interest, on income (referred to in this definition as the “attributed controlled foreign company income”) of the controlled foreign company that is included under the controlled foreign company tax regime of the particular jurisdiction for the purposes of determining the constituent entity’s taxable income in the particular jurisdiction; (b) is not allowed to be used in the particular taxation year in which it arises solely because the income tax laws of the particular jurisdiction require, in determining the constituent entity’s taxable income, that an amount that would be a tax loss of the constituent entity in the absence of the attributed controlled foreign company income in the particular taxation year be offset against the attributed controlled foreign company income in priority to the tax credit, or portion of the tax credit, being used to reduce or eliminate any covered taxes for which the constituent entity would otherwise be liable in respect of the attributed controlled foreign company income under the income tax laws of the particular jurisdiction; and (c) is, under the income tax laws of the particular jurisdiction, allowed to be used by the constituent entity, in a taxation year following the particular taxation year, to reduce or eliminate any covered taxes for which the constituent entity would otherwise be liable under the income tax laws of the particular jurisdiction in respect of income that is included in computing the constituent entity’s GloBE income or loss. ( crédit d’impôt pour report de pertes de remplacement )
Global Minimum Tax Act — G-3.3
tax means a compulsory unrequited payment to general government. ( impôt )
Global Minimum Tax Act — G-3.3
tax transparent entity , in relation to an owner, means a flow-through entity to the extent that the flow-through entity is fiscally transparent under the laws of the jurisdiction in which the owner is located. ( entité fiscalement transparente )
Global Minimum Tax Act — G-3.3 (a)
tax transparent structure means a chain of entities through which a particular entity holds an ownership interest, if the entities are (a) flow-through entities; and (b) fiscally transparent in relation to the particular entity. ( structure fiscalement transparente )
Global Minimum Tax Act — G-3.3
tax treaty means an agreement for the avoidance of double taxation with respect to taxes on income and on capital. ( convention fiscale )
Global Minimum Tax Act — G-3.3
top-up amount has the same meaning as in subsection 30 (1). ( montant complémentaire )
Global Minimum Tax Act — G-3.3
top-up percentage has the same meaning as in subsection 30 (3). ( pourcentage complémentaire )
Global Minimum Tax Act — G-3.3
total deferred tax adjustment amount has the same meaning as in subsection 25 (1). ( montant total de l’ajustement pour impôts différés )
Global Minimum Tax Act — G-3.3
transitional special allocation year , of an MNE group, means any fiscal year beginning on or before December 31, 2025 and ending on or before June 30, 2027. ( année de répartition spéciale transitoire )
Global Minimum Tax Act — G-3.3
ultimate parent entity has the same meaning as in subsection 12 (1). ( entité mère ultime )
Global Minimum Tax Act — G-3.3 (a)
unclaimed accrual , of a constituent entity of an MNE group for a fiscal year, means an increase in a deferred tax liability recorded in the financial accounts of the constituent entity for the fiscal year if (a) the increase is not expected to reverse on or before the last day of the fifth fiscal year following the fiscal year; and (b) the filing constituent entity of the MNE group elects to not include the increase in determining the constituent entity’s total deferred tax adjustment amount for the fiscal year. ( accumulation non réclamée )
Global Minimum Tax Act — G-3.3 (a)
unrelated purchaser , in respect of the transfer of a tax credit by a person, means another person that acquires the tax credit unless (a) based on all the relevant facts and circumstances, one person has control of the other or both persons are under the control of the same person or persons; (b) one of the persons owns directly or indirectly, (i) if the other person is a corporation, shares of the capital stock of the corporation that (A) give their holder at least 50% of the votes of the shareholders of the corporation, and (B) have a fair market value of at least 50% of the fair market value of all the issued and outstanding shares of the capital stock of the corporation, and (ii) in any other case, at least 50% of the beneficial interest in the other person; or (c) a third person owns, directly or indirectly, in respect of each of the other persons (i) if one or both of those other persons are corporations, shares of the capital stock of each such corporation that (A) give their holder at least 50% of the votes of the shareholders of the corporation, and (B) have a fair market value of at least 50% of the fair market value of all the issued and outstanding shares of the capital stock of the corporation, and (ii) if one or both of those persons are not corporations, at least 50% of the beneficial interest in each such person. ( acheteur non lié )
Global Minimum Tax Act — G-3.3
UTPR means a law of a jurisdiction that may reasonably be considered to have been enacted with the intention of implementing, in whole or in part, Articles 2.4 to 2.6 of the GloBE Model Rules. ( RPII )