9002.1 For the purpose of paragraph (b) of the definition “excluded property” in subsection 142.2(1) of the Act, a prescribed payment card corporation share of a taxpayer at any time means a share of the capital stock of a particular corporation if, at that time,

• (a) the particular corporation is any one of the following

  • (i) MasterCard International Incorporated,

  • (ii) MasterCard Incorporated, or

  • (iii) Visa Inc.; and

• (b) the share

  • (i) is of a class of shares that is not listed on a stock exchange,

  • (ii) is not convertible into or exchangeable for a share of the class of the capital stock of a corporation that is listed on a stock exchange, and

  • (iii) was issued by the particular corporation to the taxpayer or to a person related to the taxpayer.

9002.2 [Repealed, 2009, c. 2, s. 118]

9003. For the purpose of paragraph 142.2(3)(c) of the Act, a share described in paragraph 9002(2)(b) is prescribed in respect of all taxpayers.

9004. For the purpose of paragraph (c) of the definition “specified debt obligation” in subsection 142.2(1) of the Act, a property is a prescribed property throughout a taxation year if

• (a) the property is a direct financing lease, or any other financing arrangement, of a taxpayer that is reported as a loan in the taxpayer’s financial statements for the year prepared in accordance with generally accepted accounting principles; and

• (b) in computing the taxpayer’s income for the year, an amount is deductible under paragraph 20(1)(a) of the Act in respect of the property that is the subject of the arrangement.

Marginal note:Definitions

9100. The following definitions apply in this Part.

“fixed payment obligation”

“fixed payment obligation”, of a taxpayer, means a specified debt obligation under which

• (a) the amount and timing of each payment (other than a fee or similar payment or an amount payable because of a default by the debtor) to be made by the debtor were fixed when the taxpayer acquired the obligation and have not been changed; and

• (b) all payments are to be made in the same currency. (titre à paiements fixes)

“primary currency”

“primary currency”, of a specified debt obligation, means

• (a) the currency with which the obligation is primarily connected; and

• (b) if there is no such currency, Canadian currency. (monnaie principale)

“tax basis”

“tax basis”, of a specified debt obligation at any time to a taxpayer, has the meaning assigned by subsection 142.4(1) of the Act. (montant de base)

“total return”

“total return”, of a taxpayer from a fixed payment obligation, means the amount, measured in the primary currency of the obligation, by which

• (a) the total of all amounts each of which is the amount of a payment (other than a fee or similar payment) required to be made by the debtor under the obligation after its acquisition by the taxpayer

exceeds

• (b) the cost to the taxpayer of the obligation. (rendement total)