Global Minimum Tax Act — G-3.3 2
ary , 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 ) 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 ) 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 ) recapture account loss carry-forward has the same meaning as in subsection 37 (3). ( report des pertes du compte de récupération ) 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 ) regulation means a regulation made under this Act. ( règlement ) relevant parent entity has the same meaning as in subsection 14 (3). ( entité mère pertinente ) revenue threshold has the same meaning as in subsection 9 (2). ( seuil de chiffre d’affaires ) 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 ) 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 ) 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 ) standard constituent entity has the same meaning as in subsection 11 (3). ( entité constitutive type ) stapled structure means an arrangement en