Income Tax Regulations — 8500
l be deemed to own, at any time, that proportion of all shares of the capital stock of a corporation that are property of the partnership at that time that the fair market value at that time of the member’s interest in the partnership is of the fair market value at that time of the interests of all members in the partnership, and (g) a person who, at any time, has a right under a contract, in equity or otherwise, either immediately or in the future and either absolutely or contingently, to, or to acquire, shares of the capital stock of a corporation shall be deemed to own, at that time, those shares if one of the main reasons for the existence of the right may reasonably be considered to be that the person not be connected with an employer. (4) For the purposes of this Part, an officer who receives remuneration for holding an office shall, for any period that the officer holds the office, be deemed to render services to, and to be in the service of, the person from whom the officer receives the remuneration. (5) For the purpose of this Part, spouse and former spouse of a particular individual include another individual who is a party to a void or voidable marriage with the particular individual. (6) Where this Part provides that an amount is to be determined by aggregating the durations of periods that satisfy specified conditions, a period shall be included in determining the aggregate only if it is not part of a longer period that satisfies the conditions. (7) For the purposes of the definition active member in subsection (1), subparagraph 8503(3)(a)(v) and paragraphs 8504(7)(d), 8506(2)(c.1) and 8507(3)(a), the portion of an amount allocated to an individual at any time under a money purchase provision of a registered pension plan that is attributable to (a) forfeited amounts under the provision or earnings of the plan that are reasonably attributable to those amounts, (b) a surplus under the provision, (c) property transferred to the provision in respect of the actuarial surplus under a defined benefit provision of the plan or another registered pension plan, or (d) property transferred to the provision in respect of the surplus under another money purchase provision of the plan or under a money purchase provision of another registered pension plan shall be deemed to be a contribution made under the provision on behalf of the individual at that time. (8) Where an individual who is entitled to receive benefits (in this subsection referred to as “member benefits”) under a pension plan because of the individual’s membership in the plan is also entitled to receive other benefits (in this subsection referred to as “non-member benefits”) under the plan or under any other pension plan solely because of the participation of another individual in the plan or in the other plan, the following rules apply: (a) for the purpose of determining whether the member benefits are permissible under this Part, the non-member benefits shall be disregarded; (b) for the purpose of determining whether the non-member benefits are permissible under this Part, the member benefits shall be disregarded; and (c) for the purpose of determining a pension adjustment, pension adjustment reversal or provisional past service pension adjustment of the individual under Part LXXXIII, the non-member benefits shall be disregarded. (9) For the purposes of paragraph 147.3(6)(b) of the Act and subparagraphs 8502(d)(iv) and 8503(2)(h)(iii), if an amount is transferred in accordance with subsection 147.3(3) of the Act to a defined benefit provision (referred to in this subsection as the “current provision”) of a registered pension plan from a defined benefit provision (referred to in this subsection as the “former provision”) of another registered pension plan on behalf of all or a significant number of members whose benefits under the former provision are replaced by benefits under the current provision, each current service contribution made at a particular time under