Income Tax Act — I-3.3 135.2
the amount by which the principal amount of the eligible debt exceeds $10 million; and (b) all of the interests as a beneficiary under the trust are fixed interests if (as defined in subsection 251.2(1)) in the trust. ( unité admissible ) eligible wind-up distribution , of a trust, means a distribution of property by the trust to a person if (a) the distribution includes a share of the capital stock of the Canadian Wheat Board that is listed on a designated stock exchange; (b) the only property (other than a share described in paragraph (a)) distributed by the trust on the distribution is money denominated in Canadian dollars; (c) the distribution results in the disposition of all of the person’s interest as a beneficiary under the trust; and (d) the trust ceases to exist immediately after the distribution or immediately after the last of a series of eligible wind-up distributions (determined without reference to this paragraph) of the trust that includes the distribution. ( distribution admissible sur liquidation ) participating farmer , in respect of a trust at any time, means a person (a) who is eligible to receive units of the trust pursuant to the plan under which the trust directs its trustees to grant units to persons who have delivered grain under a contract with the Canadian Wheat Board on or after August 1, 2013; and (b) engaged in the production of grain or any person entitled, as landlord, vendor or mortgagee or hypothecary creditor, to grain produced by a person engaged in the production of grain or to any share of that grain. ( agriculteur participant ) person includes a partnership. ( personne ) Trust acquires an eligible debt (2) If, at any time, an eligible trust acquires eligible debt, the principal amount of the eligible debt is deemed not to be included in computing the income of the eligible trust for the taxation year of the eligible trust that includes that time. Disposition of eligible debt (3) If, at any time, an eligible trust disposes of eligible debt in exchange for consideration that includes the issuance of eligible shares (a) for the purpose of computing the income of the eligible trust for its taxation year that includes that time (i) an amount, in respect of the disposition of the eligible debt, equal to the fair market value of all property (other than eligible shares) received on the exchange by the trust is included, (ii) no amount in respect of the disposition of the eligible debt is included (other than the amount described in subparagraph (i)), and (iii) no amount in respect of the receipt of the eligible shares is included; (b) the cost to the eligible trust of each eligible share is deemed to be nil; (c) in computing the paid-up capital in respect of the class of the capital stock of the Canadian Wheat Board that includes the eligible shares, at any time after the shares are issued, there shall be deducted an amount equal to the amount of the paid-up capital in respect of that class at the time the shares are issued; (d) subsection 75(2) does not apply to property (i) that is held by the trust in a taxation year that ends at or after that time, and (ii) that is (A) received by the trust on the exchange, or (B) a substitute for property described in subparagraph (i); and (e) subsections 84(2) and (3) and section 85 do not apply at any time to eligible shares. Eligible trust (4) The following rules apply in respect of a trust that is an eligible trust at any time in a taxation year of the trust: (a) in computing the trust’s income for the year (i) no deduction may be made by the trust under subsection 104(6), except to the extent of the income of the trust (determined without reference to subsection 104(6)) for the year that is paid in the year, and (ii) no deduction may be made by the trust under subsection 104(6), if the trust ceased to be an eligible trust at the beginning of the following taxation year; (b) for the purposes of applying Part XII.2 in respect of the year (i) the trust’s