Income Tax Act — I-3.3 130.1
 develop any real or immovable property; (c) none of the property of the corporation consisted of (i) debts owing to the corporation that were secured on real or immovable property situated outside Canada, (ii) debts owing to the corporation by non-resident persons, except any such debts that were secured on real or immovable property situated in Canada, (iii) shares of the capital stock of corporations not resident in Canada, or (iv) real or immovable property situated outside Canada, or any leasehold interest in such property; (d) there were 20 or more shareholders of the corporation and no person would have been a specified shareholder of the corporation at any time in the year if (i) the portion of the definition specified shareholder in subsection 248(1) before paragraph (a) were read as follows: “ specified shareholder of a corporation at any time means a taxpayer who owns, directly or indirectly, at that time, more than 25% of the issued shares of any class of the capital stock of the corporation and, for the purposes of this definition,” (ii) paragraph (a) of that definition were read as follows: “(a) a taxpayer is deemed to own each share of the capital stock of a corporation owned at that time by a person related to the taxpayer,” (iii) that definition were read without reference to paragraph (d) of that definition, and (iv) paragraph 251(2)(a) were read as follows: “(a) an individual and (i) the individual’s child (as defined in subsection 70(10)) who is under 18 years of age, or (ii) the individual’s spouse or common-law partner;” (e) any holders of preferred shares of the corporation had a right, after payment to them of their preferred dividends, and payment of dividends in a like amount per share to the holders of the common shares of the corporation, to participate pari passu with the holders of the common shares in any further payment of dividends; (f) the cost amount to the corporation of such of its property as consisted of (i) debts owing to the corporation that were secured, whether by mortgages, hypothecs or in any other manner, on houses (as defined in section 2 of the National Housing Act ) or on property included within a housing project (as defined in that section as it read on June 16, 1999), and (ii) amounts of any deposits standing to the corporation’s credit in the records of (A) a bank or other corporation any of whose deposits are insured by the Canada Deposit Insurance Corporation or the Régie de l’assurance-dépôts du Québec, or (B) a credit union, plus the amount of any money of the corporation was at least 50% of the cost amount to it of all its property; (g) the cost amount to the corporation of all real or immovable property of the corporation, including leasehold interests in such property (except real or immovable property acquired by the corporation by foreclosure or otherwise after default made on a mortgage, hypothec or agreement of sale of real or immovable property) did not exceed 25% of the cost amount to it of all its property; (h) its liabilities did not exceed 3 times the amount by which the cost amount to it of all its property exceeded its liabilities, where at any time in the year the cost amount to it of such of its property as consisted of property described in subparagraphs 130.1(6)(f)(i) and 130.1(6)(f)(ii) plus the amount of any money of the corporation was less than 2/3 of the cost amount to it of all of its property; and (i) its liabilities did not exceed 5 times the amount by which the cost amount to it of all its property exceeded its liabilities, where paragraph 130.1(6)(h) is not applicable. How shareholders counted (7) In paragraph (6)(d), a trust governed by a registered pension plan or deferred profit sharing plan by which shares of the capital stock of a corporation are held shall be counted as four shareholders of the corporation for the purpose of determining the number of shareholders of the corporation, but as one shareholder for the purpose of determining w