Income Tax Regulations — 4900
n (2), and (iii) the certificate is issued as part of an issue of certificates by the issuer for a total amount of at least $25 million; (k) and (l) [Repealed, 2009, c. 2, s. 105] (m) to (n.1) [Repealed, 2007, c. 29, s. 32] (o) [Repealed, 2009, c. 2, s. 105] (p) and (p.1) [Repealed, 2007, c. 29, s. 32] (q) a debt issued by a Canadian corporation (other than a corporation with share capital or a corporation that is a connected person under the governing plan of the plan trust) where (i) the taxable income of the corporation is exempt from tax under Part I of the Act because of paragraph 149(1)(l) of the Act, and (ii) either (A) before the particular time and after 1995, the corporation (I) acquired, for a total consideration of not less than $25 million, property from Her Majesty in right of Canada or a province, and (II) put that property to a use that is the same as or similar to the use to which the property was put before the acquisition described in subclause (I), or (B) at the time of the acquisition of the debt by the plan trust, it was reasonable to expect that clause (A) would apply in respect of the debt no later than one year after the time of the acquisition; (r) a debt issued by a Canadian corporation (other than a corporation with share capital or a corporation that is a connected person under the governing plan of the plan trust) if (i) the taxable income of the corporation is exempt from tax under Part I of the Act because of paragraph 149(1)(l) of the Act, and (ii) either (A) the debt is issued by the corporation as part of an issue of debt by the corporation for an amount of at least $25 million, or (B) at the time of the acquisition of the debt by the plan trust, the corporation had issued debt as part of a single issue for an amount of at least $25 million; (s) [Repealed, 2009, c. 2, s. 105] (t) a gold or silver legal tender bullion coin (i) that is of a minimum fineness of 995 parts per 1000 in the case of gold and 999 parts per 1000 in the case of silver, (ii) that was produced by the Royal Canadian Mint, (iii) that has a fair market value at the particular time not exceeding 110 per cent of the fair market value of the coin’s gold or silver content, and (iv) that is acquired by the plan trust directly from the Royal Canadian Mint or from a corporation (in paragraphs (u) and (v) referred to as a “specified corporation”) (A) that is a bank, a trust company, a credit union, an insurance corporation or a registered securities dealer, (B) that is resident in Canada, and (C) that is a corporation whose business activities are subject by law to the supervision of a regulating authority that is the Superintendent of Financial Institutions or a similar authority of a province; (u) a gold or silver bullion bar, ingot or wafer (i) that is of a minimum fineness of 995 parts per 1000 in the case of gold and 999 parts per 1000 in the case of silver, (ii) that was produced by a metal refiner included in the London Bullion Market Association’s good delivery list of acceptable refiners for gold or silver, as the case may be, (iii) that bears the hallmark of the metal refiner that produced it and a stamp indicating its fineness and its weight, and (iv) that is acquired by the plan trust either directly from the metal refiner that produced it or from a specified corporation; (v) a certificate issued by a specified corporation or the Royal Canadian Mint representing a claim of the holder of the certificate to property held by the issuer of the certificate, where (i) the property would be property described in paragraph (t) or (u) if those paragraphs were read without reference to subparagraphs (t)(iv) and (u)(iv), respectively, and (ii) the certificate is acquired by the plan trust directly from the issuer of the certificate or from a specified corporation; or (w) an American Depositary Receipt where the property represented by the receipt is listed on a designated stock exchange. (2) For the purposes of paragraph (c.1) of t