Income Tax Act — I-3.3 248
ular time to have been issued at the particular time and to be at and immediately after the particular time a short-term preferred share, and for the purposes of this paragraph, where a guarantee agreement in respect of a share is given at any particular time after December 15, 1987, otherwise than pursuant to a written arrangement to do so entered into before December 16, 1987, the share shall be deemed to have been issued at the particular time and the guarantee agreement shall be deemed to have been given as part of a series of transactions that included the issuance of the share, (i) a share that is, at the time a dividend is paid thereon, 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 prescribed share shall, notwithstanding any other provision of this definition, be deemed not to be a short-term preferred share at that time, and (j) specified person has the meaning assigned by paragraph (h) of the definition taxable preferred share in this subsection; ( action privilégiée à court terme ) SIFT partnership has the meaning assigned by section 197; ( société de personnes intermédiaire de placement déterminée ) SIFT partnership balance-due day , in respect of a taxation year of a SIFT partnership, means the day on or before which the partnership is required to file a return for the taxation year under section 229 of the Income Tax Regulations ; ( date d’échéance du solde ) SIFT trust has the meaning assigned by section 122.1; ( fiducie intermédiaire de placement déterminée ) SIFT trust wind-up event means a distribution by a particular trust resident in Canada of property to a taxpayer in respect of which the following conditions are met: (a) the distribution occurs before 2013, (b) there is a resulting disposition of all of the taxpayer’s interest as a beneficiary under the particular trust, (c) the particular trust is (i) a SIFT wind-up entity, (ii) a trust whose only beneficiary throughout the period (referred to in this definition as the “qualifying period”) that begins on July 14, 2008 and that ends at the time of the distribution is another trust that throughout the qualifying period (A) is resident in Canada, and (B) is a SIFT wind-up entity or a trust described by this subparagraph, or (iii) a trust whose only beneficiary at the time of distribution is another trust that throughout the qualifying period (A) is resident in Canada, (B) is a SIFT wind-up entity or a trust described by subparagraph (ii), and (C) is a majority interest beneficiary (within the meaning that would be assigned by section 251.1 if the references in the definition majority interest beneficiary in subsection 251.1(3) to “50%” were read as references to “25%”) of the particular trust, (d) the particular trust ceases to exist immediately after the distribution or immediately after the last of a series of SIFT trust wind-up events (determined without reference to this paragraph) of the particular trust that includes the distribution, and (e) the property was not acquired by the particular trust as a result of a transfer or an exchange (i) that is (A) a qualifying exchange as defined in subsection 132.2(1) or a qualifying disposition as defined in subsection 107.4(1), (B) made after February 2, 2009, and (C) from any person other than a SIFT wind-up entity, or (ii) to which any of sections 51, 85, 85.1, 86, 87, 88, 107.4 or 132.2 applies, of another property acquired as a result of a transfer or an exchange described by subparagraph (i) or this subparagraph; ( fait lié à la conversion d’une EIPD-fiducie ) SIFT wind-up corporation , in respect of a SIFT wind-up entity, means at any particular time a corporation (a) that, at any time that is after July 13, 2008 and before the earlier of the particular time and January 1, 2013, owns all of the equity in the SIFT wind-up entity, or (b) shares of the capital stock of which are at or before the