Income Tax Act — I-3.3 251.2
 same meaning as in subsection 251.1(3). ( groupe de bénéficiaires détenant une participation majoritaire ) majority-interest group of partners has the same meaning as in subsection 251.1(3). ( groupe d’associés détenant une participation majoritaire ) person includes a partnership. ( personne ) portfolio investment fund [Repealed, 2016, c. 12, s. 65] specified right , held at any time by a person in respect of a trust, means a right under a contract, in equity or otherwise, to acquire, either immediately or in the future and either absolutely or contingently, equity of the trust, or to cause the trust to redeem or cancel equity of the trust, unless the right is not exercisable at that time because its exercise is contingent on the death, bankruptcy or permanent disability of an individual. ( droit déterminé ) subsidiary , of a particular person at any time, means a corporation, partnership or trust (in this definition referred to as the “subject entity”) where (a) the particular person holds at that time property (i) that is equity of the subject entity, or (ii) that derives all or part of its fair market value, directly or indirectly, from equity of the subject entity; and (b) the total of the following amounts is at that time equal to more than 50% of the equity value of the subject entity: (i) each amount that is the fair market value at that time of equity of the subject entity that is held at that time by the particular person or a person with whom the particular person is affiliated, and (ii) each amount (other than an amount described in subparagraph (i)) that is the portion of the fair market value at that time — derived directly or indirectly from equity of the subject entity — of a property that is held at that time by the particular person or a person with whom the particular person is affiliated. ( filiale ) Loss restriction event (2) For the purposes of this Act, a taxpayer is at any time subject to a loss restriction event if (a) the taxpayer is a corporation and at that time control of the corporation is acquired by a person or group of persons; or (b) the taxpayer is a trust and (i) that time is after March 20, 2013 and after the time at which the trust is created, and (ii) at that time a person becomes a majority-interest beneficiary, or a group of persons becomes a majority-interest group of beneficiaries, of the trust. Trusts — exceptions (3) For the purposes of paragraph (2)(b), a person is deemed not to become a majority-interest beneficiary, and a group of persons is deemed not to become a majority-interest group of beneficiaries, as the case may be, of a particular trust solely because of (a) the acquisition of equity of the particular trust by (i) a particular person from another person with whom the particular person was affiliated immediately before the acquisition, (ii) a particular person who was affiliated with the particular trust immediately before the acquisition, (iii) an estate from an individual, if the estate arose on and as a consequence of the death of the individual and the estate acquired the equity from the individual as a consequence of the death, or (iv) a particular person from an estate that arose on and as a consequence of the death of an individual, if the estate acquired the equity from the individual as a consequence of the death and the individual was affiliated with the particular person immediately before the death; (b) a variation in the terms of the particular trust, the satisfaction of, or failure to satisfy, a condition under the terms of the particular trust, the exercise by any person of, or the failure by any person to exercise, a power, or (without limiting the generality of the foregoing) the redemption, surrender or termination of equity of the particular trust at any time, if each majority-interest beneficiary, and each member of a majority-interest group of beneficiaries, of the particular trust immediately after that time was affiliated with the particular trust