Income Tax Act — I-3.3 248
ss 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of a corporation owned at that time by the trust; ( actionnaire déterminé ) specified synthetic equity arrangement [Repealed, 2026, c. 3, s. 94] specified unitholder , of a partnership or trust (referred to in this definition as the “entity”), the interests in which are described by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 ) split income has the meaning assigned by subsection 120.4(1); ( revenu fractionné ) 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 ) 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 ) 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 ) 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 ) 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 ) supplementary unemployment benefit plan has the meaning assigned by subsection 145(1); ( régime de prestations supplémentaires de chômage ) 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 ) synthetic disposition period , of a synthetic disposition arrangement, means the definite or indefinite period of time during whi