Income Tax Act — I-3.3 248
entered into by the connected dealer, it can reasonably be considered that the particular person or connected dealer knew or ought to have known that the effect described in paragraph (b) would result; ( opération de couverture déterminée ) specified individual has the meaning assigned by subsection 120.4(1); ( particulier déterminé ) specified investment business has the meaning assigned by subsection 125(7); ( entreprise de placement déterminée ) specified member of a partnership in a fiscal period or taxation year of the partnership, as the case may be, means (a) any member of the partnership who is a limited partner (within the meaning assigned by subsection 96(2.4)) of the partnership at any time in the period or year, and (b) any member of the partnership, other than a member who is (i) actively engaged in those activities of the partnership business that are other than the financing of the partnership business, or (ii) carrying on a similar business as that carried on by the partnership in its taxation year, otherwise than as a member of a partnership, on a regular, continuous and substantial basis throughout that part of the period or year during which the business of the partnership is ordinarily carried on and during which the member is a member of the partnership; ( associé déterminé ) specified mutual fund trust [Repealed, 2026, c. 3, s. 94] specified pension plan means a prescribed arrangement; ( régime de pension déterminé ) specified proportion , of a member of a partnership for a fiscal period of the partnership, means the proportion that the member’s share of the total income or loss of the partnership for the partnership’s fiscal period is of the partnership’s total income or loss for that period and, for the purpose of this definition, where that income or loss for a period is nil, that proportion shall be computed as if the partnership had income for that period in the amount of $1,000,000; ( proportion déterminée ) specified securities lending arrangement has the same meaning as in subsection 260(1); ( mécanisme de prêt de valeurs mobilières déterminé ) specified shareholder of a corporation in a taxation year means a taxpayer who owns, directly or indirectly, at any time in the year, not less than 10% of the issued shares of any class of the capital stock of the corporation or of any other corporation that is related to the corporation and, for the purposes of this definition, (a) a taxpayer shall be deemed to own each share of the capital stock of a corporation owned at that time by a person with whom the taxpayer does not deal at arm’s length, (b) each beneficiary of a trust shall be deemed to own that proportion of all such shares owned by the trust at that time that the fair market value at that time of the beneficial interest of the beneficiary in the trust is of the fair market value at that time of all beneficial interests in the trust, (c) each member of a partnership shall be deemed to own that proportion of all the shares of any class 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, (d) an individual who performs services on behalf of a corporation that would be carrying on a personal services business if the individual or any person related to the individual were at that time a specified shareholder of the corporation shall be deemed to be a specified shareholder of the corporation at that time if the individual, or any person or partnership with whom the individual does not deal at arm’s length, is, or by virtue of any arrangement may become, entitled, directly or indirectly, to not less than 10% of the assets or the shares of any class of the capital stock of the corporation or any corporation related thereto, and (e) notwithstanding paragraph (b), where a beneficiary’s share of t