GreatNorthCollective/greatnorth-canada-federal-laws-text huggingface dataset:
Income Tax Act — I-3.3
specified investment business has the meaning assigned by subsection 125(7); ( entreprise de placement déterminée )
Income Tax Act — I-3.3 (a)
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 )
Income Tax Act — I-3.3
specified mutual fund trust [Repealed, 2026, c. 3, s. 94]
Income Tax Act — I-3.3
specified pension plan means a prescribed arrangement; ( régime de pension déterminé )
Income Tax Act — I-3.3
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 )
Income Tax Act — I-3.3
specified securities lending arrangement has the same meaning as in subsection 260(1); ( mécanisme de prêt de valeurs mobilières déterminé )
Income Tax Act — I-3.3 (a)
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 the income or capital of the trust depends on the exercise by any person of, or the failure by any person to exercise, any discretionary power, the beneficiary shall be deemed to own each share of the capital stock of a corporation owned at that time by the trust; ( actionnaire déterminé )
Income Tax Act — I-3.3
specified synthetic equity arrangement [Repealed, 2026, c. 3, s. 94]
Income Tax Act — I-3.3
specified unitholder , of a partnership or trust (referred to in this definition as the “entity”), the interests in which are described by reference to units, means a taxpayer who would be a specified shareholder of the entity if the entity were a corporation and each unit of the entity were a share of a class of the corporation having the same attributes as the unit; ( détenteur d’unité déterminé )
Income Tax Act — I-3.3
split income has the meaning assigned by subsection 120.4(1); ( revenu fractionné )
Income Tax Act — I-3.3
stock dividend includes any dividend (determined without reference to the definition dividend in this subsection) paid by a corporation to the extent that it is paid by the issuance of shares of any class of the capital stock of the corporation; ( dividende en actions )
Income Tax Act — I-3.3
subsidiary controlled corporation means a corporation more than 50% of the issued share capital of which (having full voting rights under all circumstances) belongs to the corporation to which it is subsidiary; ( filiale contrôlée )
Income Tax Act — I-3.3
subsidiary wholly-owned corporation means a corporation all the issued share capital of which (except directors’ qualifying shares) belongs to the corporation to which it is subsidiary; ( filiale à cent pour cent )
Income Tax Act — I-3.3 (a)
substantive CCPC means a private corporation (other than a Canadian-controlled private corporation) that (a) is controlled, directly or indirectly in any manner whatever, by one or more individuals resident in Canada, or (b) would, if each share of the capital stock of a corporation that is owned by a Canadian resident individual were owned by a particular individual, be controlled by the particular individual; ( SPCC en substance )
Income Tax Act — I-3.3 (a)
superannuation or pension benefit includes any amount received out of or under a superannuation or pension fund or plan (including, except for the purposes of subparagraph 56(1)(a)(i), a pooled registered pension plan) and, without restricting the generality of the foregoing, includes any payment made to a beneficiary under the fund or plan or to an employer or former employer of the beneficiary under the fund or plan (a) in accordance with the terms of the fund or plan, (b) resulting from an amendment to or modification of the fund or plan, or (c) resulting from the termination of the fund or plan; ( prestation de retraite ou de pension )
Income Tax Act — I-3.3
supplementary unemployment benefit plan has the meaning assigned by subsection 145(1); ( régime de prestations supplémentaires de chômage )
Income Tax Act — I-3.3 (a)
synthetic disposition arrangement , in respect of a property owned by a taxpayer, means one or more agreements or other arrangements that (a) are entered into by the taxpayer or by a person or partnership that does not deal at arm’s length with the taxpayer, (b) have the effect, or would have the effect if entered into by the taxpayer instead of the person or partnership, of eliminating all or substantially all the taxpayer’s risk of loss and opportunity for gain or profit in respect of the property for a definite or indefinite period of time, and (c) can, in respect of any agreement or arrangement entered into by a person or partnership that does not deal at arm’s length with the taxpayer, reasonably be considered to have been entered into, in whole or in part, with the purpose of obtaining the effect described in paragraph (b); ( arrangement de disposition factice )
Income Tax Act — I-3.3
synthetic disposition period , of a synthetic disposition arrangement, means the definite or indefinite period of time during which the synthetic disposition arrangement has, or would have, the effect described in paragraph (b) of the definition synthetic disposition arrangement in this subsection; ( période de disposition factice )
Income Tax Act — I-3.3 (a)
synthetic equity arrangement in respect of a DRA share of a person or partnership (referred to in this definition as the particular person ), (a) means one or more agreements or other arrangements that (i) are entered into by the particular person, by a person or partnership that does not deal at arm’s length with, or is affiliated with, the particular person (referred to in this definition as a “connected person”) or, for greater certainty, by any combination of the particular person and connected persons, with one or more persons or partnerships (referred to in this definition as a “counterparty”), (ii) have the effect, or would have the effect, if each agreement entered into by a connected person were entered into by the particular person, of eliminating all or substantially all the particular person’s risk of loss and opportunity for gain or profit in respect of the DRA share, and, for greater certainty, opportunity for gain or profit includes rights to, benefits from and distributions on a share, and (iii) if entered into by a connected person, can reasonably be considered to have been entered into with the knowledge, or where there ought to have been the knowledge, that the effect described in subparagraph (ii) would result, and (b) does not include (i) [Repealed, 2026, c. 3, s. 94] (ii) one or more agreements or other arrangements that, but for this subparagraph, would be a synthetic equity arrangement, in respect of a share owned by the particular person (in this subparagraph referred to as the synthetic short position ), if (A) the particular person has entered into one or more other agreements or other arrangements (other than, for greater certainty, an agreement under which the share is acquired or an agreement or arrangement under which the particular person receives a deemed dividend and is provided with all or substantially all of the risk of loss and opportunity for gain or profit in respect of the share) that have the effect of providing all or substantially all of the risk of loss and opportunity for gain or profit in respect of the share to the particular person (in this subparagraph referred to as the synthetic long position ), (B) the synthetic short position has the effect of offsetting all amounts included or deducted in computing the income of the particular person with respect to the synthetic long position, and (C) the synthetic short position was entered into for the purpose of obtaining the effect referred to in clause (B), and (iii) an agreement to purchase the shares of a corporation, or a purchase agreement that is part of a series of agreements to purchase the shares of a corporation, under which a counterparty or a group of counterparties each member of which is affiliated with every other member acquires control of the corporation that has issued the shares being purchased, unless the main reason for establishing, incorporating or operating the corporation is to have this subparagraph apply; ( arrangement de capitaux propres synthétiques )
Income Tax Act — I-3.3
synthetic equity arrangement chain [Repealed, 2026, c. 3, s. 94]
Income Tax Act — I-3.3
tar sands means bituminous sands or oil shales extracted, otherwise than by a well, from a mineral resource, but, for the purpose of applying sections 13 and 20 and any regulations made for the purpose of paragraph 20(1)(a) in respect of property acquired after March 6, 1996, includes material extracted by a well from a deposit of bituminous sands or oil shales; ( sables asphaltiques )
Income Tax Act — I-3.3
taxable Canadian corporation has the meaning assigned by subsection 89(1); ( société canadienne imposable )
Income Tax Act — I-3.3
taxable capital gain has the meaning assigned by section 38; ( gain en capital imposable )
Income Tax Act — I-3.3
taxable dividend has the meaning assigned by subsection 89(1); ( dividende imposable )
Income Tax Act — I-3.3
taxable income has the meaning assigned by subsection 2(2), except that in no case may a taxpayer’s taxable income be less than nil; ( revenu imposable )
Income Tax Act — I-3.3
taxable income earned in Canada means a taxpayer’s taxable income earned in Canada determined in accordance with Division D of Part I, except that in no case may a taxpayer’s taxable income earned in Canada be less than nil; ( revenu imposable gagné au Canada )
Income Tax Act — I-3.3
taxable net gain from dispositions of listed personal property has the meaning assigned by section 41; ( gain net imposable )
Income Tax Act — I-3.3 (a)
hare 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 a corporation shall be read without reference to that part of the agreement under which a person agrees to acquire the share for an amount (i) in the case of a share the agreement in respect of which provides that the share is to be acquired within 60 days after the day on which the agreement was entered into, that does not exceed the greater of the fair market value of the share at the time the agreement was entered into, determined without reference to the agreement, and the fair market value of the share at the time of the acquisition, determined without reference to the agreement, or (ii) that does not exceed the fair market value of the share at the time of the acquisition, determined without reference to the agreement, or for an amount determined by reference to the assets or earnings of the corporation where that determination may reasonably be considered to be used to determine an amount that does not exceed the fair market value of the share at the time of the acquisition, determined without reference to the agreement, (g) where (i) it may reasonably be considered that the dividends that may be declared or paid to a shareholder at any time on a share (other than 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) of the capital stock of a corporation issued after December 15, 1987 or acquired after June 15, 1988 are derived primarily from dividends received on taxable preferred shares of the capital stock of another corporation, and (ii) it may reasonably be considered that the share was issued or acquired as part of a transaction or event or series of transactions or events one of the main purposes of which was to avoid or limit the application of Part IV.1 or VI.1, the share shall be deemed at that time to be a taxable preferred share, and (h) specified person , in relation to any particular person, means another person with whom the particular person does not deal at arm’s length or any partnership or trust of which the particular person or the other person is a member or beneficiary, respectively; ( action privilégiée imposable )
Income Tax Act — I-3.3
tax-indifferent investor [Repealed, 2026, c. 3, s. 94]
Income Tax Act — I-3.3
taxpayer includes any person whether or not liable to pay tax; ( contribuables )
Income Tax Act — I-3.3
tax shelter has the meaning assigned by subsection 237.1(1); ( abri fiscal )
Income Tax Act — I-3.3
tax treaty with a country at any time means a comprehensive agreement or convention for the elimination of double taxation on income, between the Government of Canada and the government of the country, which has the force of law in Canada at that time; ( traité fiscal )
Income Tax Act — I-3.3 (a)
10/8 policy means a life insurance policy (other than an annuity) where (a) an amount is or may become (i) payable, under the terms of a borrowing, to a person or partnership that has been assigned an interest in the policy or in an investment account in respect of the policy, or (ii) payable (within the meaning assigned by the definition amount payable in subsection 138(12)) under a policy loan (as defined in subsection 148(9)) made in accordance with the terms and conditions of the policy, and (b) either (i) the return credited to an investment account in respect of the policy (A) is determined by reference to the rate of interest on the borrowing or policy loan, as the case may be, described in paragraph (a), and (B) would not be credited to the account if the borrowing or policy loan, as the case may be, were not in existence, or (ii) the maximum amount of an investment account in respect of the policy is determined by reference to the amount of the borrowing or policy loan, as the case may be, described in paragraph (a); ( police 10/8 )
Income Tax Act — I-3.3
testamentary trust has the meaning assigned by subsection 108(1); ( fiducie testamentaire )
Income Tax Act — I-3.3
TFSA , being a tax-free savings account, has the meaning assigned by subsection 146.2(5); ( compte d’épargne libre d’impôt )
Income Tax Act — I-3.3
timber resource property has the meaning assigned by subsection 13(21); ( avoir forestier )
Income Tax Act — I-3.3
total pension adjustment reversal of a taxpayer for a calendar year has the meaning assigned by regulation; ( facteur d’équivalence rectifié total )
Income Tax Act — I-3.3
transferred capacity has the same meaning as in subsection 18.2(1); ( capacité transférée )
Income Tax Act — I-3.3
transmission equipment has the same meaning as in subsection 1104(13) of the Income Tax Regulations ; ( matériel de transmission )
Income Tax Act — I-3.3
Treasury Board means the Treasury Board established by section 5 of the Financial Administration Act ; ( Conseil du Trésor )
Income Tax Act — I-3.3
treaty-protected business of a taxpayer at any time means a business in respect of which any income of the taxpayer for a period that includes that time would, because of a tax treaty with another country, be exempt from tax under Part I; ( entreprise protégée par traité )
Income Tax Act — I-3.3
treaty-protected property of a taxpayer at any time means property any income or gain from the disposition of which by the taxpayer at that time would, because of a tax treaty with another country, be exempt from tax under Part I; ( bien protégé par traité )
Income Tax Act — I-3.3
trust has the meaning assigned by subsection 104(1) and, unless the context otherwise requires, includes an estate; ( fiducie )
Income Tax Act — I-3.3 (a)
trust account number means the number (other than a business number) (a) used by the Minister to identify a trust, and (b) of which the Minister has notified the trust; ( numéro de compte en fiducie )
Income Tax Act — I-3.3
undepreciated capital cost to a taxpayer of depreciable property of a prescribed class has the meaning assigned by subsection 13(21); ( fraction non amortie du coût en capital )
Income Tax Act — I-3.3
unit trust has the meaning assigned by subsection 108(2); ( fiducie d’investissement à participation unitaire )
Income Tax Act — I-3.3
unused RRSP deduction room of a taxpayer at the end of a taxation year has the meaning assigned by subsection 146(1); ( déductions inutilisées au titre des REER )
Income Tax Act — I-3.3
unused scientific research and experimental development tax credit of a taxpayer for a taxation year has the meaning assigned by subsection 127.3(2); ( partie inutilisée du crédit d’impôt pour des activités de recherche scientifique et de développement expérimental )
Income Tax Act — I-3.3
unused share-purchase tax credit of a taxpayer for a taxation year has the meaning assigned by subsection 127.2(6); ( partie inutilisée du crédit d’impôt à l’achat d’actions )
Income Tax Act — I-3.3 (a)
worker cooperative means a corporation that, at all relevant times, satisfies the following conditions: (a) the corporation is resident in Canada, (b) the corporation was incorporated or continued by or under the provisions of a law, of Canada or of a province, that provide for the establishment of the corporation as a cooperative corporation or that provide for the establishment of cooperative corporations, (c) the corporation is established for the purpose of providing employment to its members, (d) the corporation would be controlled by a particular person if each membership share of the capital stock of the corporation that is owned by a qualifying cooperative worker were owned by the particular person, (e) at least 75% of all individuals employed by the corporation and all qualifying cooperative businesses controlled by the corporation (other than an employee who has not completed an applicable probationary period, which may not exceed 12 months) are holders of a membership share of the corporation, (f) each initial membership share provided to an employee of the corporation and any qualifying cooperative business controlled by the corporation is (i) issued in exchange for a payment of a nominal amount determined in the same manner for all members described in the definition qualifying cooperative worker , and (ii) offered to each employee following their completion of an applicable probationary period, which may not exceed 12 months, (g) at least one-third of the directors of the corporation are qualifying cooperative workers of the corporation, (h) not more than 40% of the directors of the corporation consist of individuals each of whom, immediately before the time of a qualifying cooperative conversion that involved the corporation, owned, directly or indirectly, together with any person or partnership that is related to or affiliated with the director, 50% or more of the fair market value of the shares of the capital stock or indebtedness of the corporation or a qualifying cooperative business controlled by the corporation, and (i) the by-laws of the corporation provide a procedure for allocating, crediting or distributing any surplus earnings of the corporation, including that not less than 50% of those earnings must be paid on the basis of the remuneration earned by the qualifying cooperative workers from the corporation or the labour contributed by those members to the corporation; ( coopérative de travailleurs )
Income Tax Act — I-3.3
zero-emission passenger vehicle , of a taxpayer, means an automobile of the taxpayer that is included in Class 54 of Schedule II to the Income Tax Regulations ; ( voiture de tourisme zéro émission )
Income Tax Act — I-3.3 (a)
zero-emission vehicle , of a taxpayer, means a motor vehicle that (a) is a plug-in hybrid that meets prescribed conditions or is fully (i) electric, or (ii) powered by hydrogen, (b) is acquired, and becomes available for use, by the taxpayer after March 18, 2019 and before 2034, (c) does not meet any of the following conditions: (i) it is a vehicle in respect of which the taxpayer has, at any time, made an election under subsection 1103(2j) of the Income Tax Regulations , (ii) it is a vehicle in respect of which assistance has been paid by the Government of Canada under a prescribed program, and (iii) if the vehicle was acquired before March 2, 2020, either (A) it has been used, or acquired for use, for any purpose before it was acquired by the taxpayer, or (B) it is a vehicle in respect of which an amount has been deducted under paragraph 20(1)(a) or subsection 20(16) by another person or partnership, and (d) would be an accelerated investment incentive property or a reaccelerated investment incentive property of the taxpayer if subsections 1104(4) and (4.01) of the Income Tax Regulations were read without their exclusions for property included in Class 54 or Class 55 of Schedule II to those Regulations. ( véhicule zéro émission )
Income Tax Act — I-3.3
disclaimer includes a renunciation of a succession made under the laws of the Province of Quebec that is not made in favour of any person, but does not include any disclaimer made after the period ending 36 months after the death of the taxpayer unless written application therefor has been made to the Minister by the taxpayer’s legal representative within that period and the disclaimer is made within such longer period as the Minister considers reasonable in the circumstances; ( renonciation )