Income Tax Act — I-3.3 248
l to the particular share, or (III) a dividend on a share that, during the term of the arrangement, can reasonably be expected to provide to a holder of the share the same or substantially the same proportionate risk of loss or opportunity for gain as the particular share, and (B) that, if paid, would be deemed by subsection 260(5.1) to have been received by that other person or partnership, as the case may be, as a taxable dividend, (b.1) any specified hedging transaction, in respect of a DRA share of the person, and (c) any synthetic equity arrangement (other than a specified hedging transaction), in respect of a DRA share of the person; ( mécanisme de transfert de dividendes ) (d) [Repealed, 2026, c. 3, s. 94] DRA share , of a person or partnership, means a share (a) that is owned by the person or partnership, (b) in respect of which the person or partnership is deemed to have received a dividend under subsection 260(5.1) and is provided with all or substantially all of the risk of loss and opportunity for gain or profit under an agreement or arrangement, (c) that is held by a trust under which the person or partnership is a beneficiary and in respect of which the person or partnership is deemed to have received a dividend as a result of a designation by the trust under subsection 104(19), (d) in respect of which the person or partnership is deemed to have received a dividend under subsection 82(2), or (e) in any other case, in respect of which the person or partnership is (or would be in the absence of subsection 112(2.3)) entitled to a deduction under subsection 112(1) in respect of dividends received on the share; ( action de mécanisme de transfert de dividendes ou AMTD ) eligible capital amount [Repealed, 2016, c. 12, s. 63] eligible capital expenditure [Repealed, 2016, c. 12, s. 63] eligible capital property [Repealed, 2016, c. 12, s. 63] eligible dividend has the meaning assigned by subsection 89(1); ( dividende déterminé ) eligible funeral arrangement has the meaning assigned by subsection 148.1(1); ( arrangement de services funéraires ) eligible relocation means a relocation of a taxpayer in respect of which the following apply: (a) the relocation occurs to enable the taxpayer (i) to carry on a business or to be employed at a location (in section 62 and this definition referred to as “the new work location”) that is, except if the taxpayer is absent from but resident in Canada, in Canada, or (ii) to be a student in full-time attendance enrolled in a program at a post-secondary level at a location of a university, college or other educational institution (in section 62 and this definition referred to as “the new work location”), (b) the taxpayer ordinarily resided before the relocation at a residence (in section 62 and this definition referred to as “the old residence”) and ordinarily resided after the relocation at a residence (in section 62 and this definition referred to as “the new residence”), (c) except if the taxpayer is absent from but resident in Canada, both the old residence and the new residence are in Canada, and (d) the distance between the old residence and the new work location is not less than 40 kilometres greater than the distance between the new residence and the new work location; ( réinstallation admissible ) emissions allowance means an allowance, credit or similar instrument that represents a unit of emissions that can be used to satisfy a requirement under the laws of Canada or a province governing emissions of a regulated substance, such as greenhouse gas emissions; ( droit d’émissions ) emissions obligation means an obligation to surrender an emissions allowance, or an obligation that can otherwise be satisfied through the use of an emissions allowance, under a law of Canada or a province governing emissions of a regulated substance; ( obligation d’émissions ) employed means performing the duties of an office or employment; ( employé (être)) employee includes officer; ( employé ) employee b