Income Tax Act — I-3.3 (a)
 deposit with, or on behalf of, the shareholder or any specified person in relation to the shareholder given (A) to ensure that any loss that the shareholder or a specified person in relation to the shareholder may sustain by reason of the ownership, holding or disposition of the share or any other property is limited in any respect, or (B) to ensure that the shareholder or a specified person in relation to the shareholder will derive earnings by reason of the ownership, holding or disposition of the share or any other property, and the guarantee agreement was given as part of a transaction or event or a series of transactions or events that included the issuance of the share and, for the purposes of this paragraph, where a guarantee agreement in respect of a share is given at any particular time after 8:00 p.m. Eastern Daylight Saving Time, June 18, 1987, otherwise than pursuant to a written arrangement to do so entered into before 8:00 p.m. Eastern Daylight Saving Time, June 18, 1987, the share shall be deemed to have been issued at the particular time and the guarantee agreement shall be deemed to have been given as part of a series of transactions that included the issuance of the share, but does not include a share that is at the particular time a prescribed share or a share described in paragraph (e) of the definition term preferred share in this subsection during the applicable time period referred to in that paragraph and, for the purposes of this definition, (c) the dividend entitlement of a share of the capital stock of a corporation shall be deemed not to be fixed, limited to a maximum or established to be not less than a minimum where all dividends on the share are determined solely by reference to the dividend entitlement of another share of the capital stock of the corporation or of another corporation that controls the corporation that would not be a taxable preferred share if (i) this definition were read without reference to paragraph (f), (ii) the other share were issued after June 18, 1987, and (iii) the other share were not a grandfathered share, a prescribed share or a share described in paragraph (e) of the definition term preferred share in this subsection, (d) the liquidation entitlement of a share of the capital stock of a corporation shall be deemed not to be fixed, limited to a maximum or established to be not less than a minimum where all the liquidation entitlement is determinable solely by reference to the liquidation entitlement of another share of the capital stock of the corporation or of another corporation that controls the corporation that would not be a taxable preferred share if (i) this definition were read without reference to paragraph (f), (ii) the other share were issued after June 18, 1987, and (iii) the other share were not a grandfathered share, a prescribed share or a share described in paragraph (e) of the definition term preferred share in this subsection, (e) where at any particular time after 8:00 p.m. Eastern Daylight Saving Time, June 18, 1987, otherwise than pursuant to a written arrangement to do so entered into before 8:00 p.m. Eastern Daylight Saving Time, June 18, 1987, the terms or conditions of a share of the capital stock of a corporation that are relevant to any matter referred to in any of subparagraphs (b)(i) to (b)(iv) are established or modified or any agreement in respect of any such matter, to which the corporation or a specified person in relation to the corporation is a party, is changed or entered into, the share shall, for the purpose of determining after the particular time whether it is a taxable preferred share, be deemed to have been issued at that particular time, unless (i) the share is a share described in paragraph (b) of the definition grandfathered share in this subsection, and (ii) the particular time is before December 16, 1987 and before the time at which the share is first issued, (f) an agreement in respect of a share of the capital stock of