Income Tax Act — I-3.3 183.3
Definitions 183.3 (1) The following definitions apply in this Part. covered entity for a taxation year, means an entity that is a corporation, trust or partnership if at any time in the taxation year (a) equity of the entity is listed on a designated stock exchange; and (b) the entity is (i) a corporation resident in Canada (other than a mutual fund corporation), (ii) a trust that (A) is a real estate investment trust (as defined in subsection 122.1(1)), (B) is a SIFT trust, or (C) would be a SIFT trust (other than a mutual fund trust that has one or more classes of units in continuous distribution) if (I) each reference in paragraph (a) of the definition non-portfolio property in subsection 122.1(1) to “subject entity” were read as “corporation, partnership or trust” and paragraph (c) of that definition were read without reference to the words “in Canada”, (II) paragraph (a) of the definition Canadian real, immovable or resource property in subsection 248(1) were read without reference to the words “situated in Canada”, and (III) the definitions timber resource property in subsection 13(21) and Canadian resource property in subsection 66(15) were read without references to the words “in Canada”, or (iii) a partnership that (A) is a SIFT partnership, or (B) would be a SIFT partnership if (I) each reference in paragraph (a) of the definition non-portfolio property in subsection 122.1(1) to “subject entity” were read as “corporation, partnership or trust” and paragraph (c) of that definition were read without reference to the words “in Canada”, (II) paragraph (a) of the definition Canadian real, immovable or resource property in subsection 248(1) were read without reference to the words “situated in Canada”, and (III) the definitions timber resource property in subsection 13(21) and Canadian resource property in subsection 66(15) were read without references to the words “in Canada”. ( entité visée ) equity of an entity, means, if the entity is (a) a corporation, a share of the capital stock of the corporation; (b) a trust, an income or capital interest in the trust; and (c) a partnership, an interest as a member of the partnership. ( capitaux propres ) qualifying issuance means any portion of an issuance that is made (a) in exchange for (i) cash, (ii) a bond, debenture, note or other security (other than equity) of the covered entity that was issued solely for cash consideration, or that was issued in an exchange described in paragraph (c), the terms of which confer on the holder the right to make the exchange, or (iii) any combination of properties described in subparagraph (i) or (ii); (b) to an employee of the covered entity (or an entity related to the covered entity) in the course of the employee’s employment; or (c) to a person or partnership, with which the covered entity deals at arm’s length and is not affiliated, in exchange for property used in an active business carried on by the covered entity or by a specified affiliate of the covered entity. ( émission admissible ) reorganization transaction means a redemption, acquisition or cancellation of equity by a covered entity that is made (a) on an exchange of equity by a holder for consideration that includes equity (other than substantive debt) of (i) the covered entity, (ii) another entity that is related to the covered entity immediately before the exchange and is a covered entity for its taxation year that includes the exchange, or (iii) another covered entity that controls the covered entity (or an amalgamated successor entity of the covered entity) immediately after the exchange; (b) on an amalgamation of the covered entity with one or more other predecessor corporations to which subsection 87(1) applies if a holder of that equity, immediately before the amalgamation, receives consideration that includes equity (other than substantive debt) of the new corporation (within the meaning of subsection 87(1)) for the disposition of their equity on the amalgamation; (b.1