Eastern Daylight Saving Time, June 18, 1987” were read as references to “December 15, 1987”,
and, for the purposes of this definition,
(g)where the terms or conditions of an established agreement were amended after November 16, 1978, the agreement shall be deemed to have been made after that date,
(h)where
(i)at any particular time the terms or conditions of a share issued pursuant to an established agreement or of any agreement relating to such a share have been changed,
(ii)under the terms or conditions of
(A)a share of a class of the capital stock of the issuing corporation issued before November 17, 1978 (other than a share that was listed on November 16, 1978 on a prescribed stock exchange in Canada),
(B)a share issued pursuant to an established agreement,
(C)any agreement between the issuing corporation and the owner of a share described in clause (A) or (B), or
(D)any agreement relating to a share described in clause (A) or (B) made after October 23, 1979,
the owner thereof could at any particular time after November 16, 1978 require, either alone or together with one or more taxpayers, the redemption, acquisition, cancellation, conversion or reduction of the paid-up capital of the share otherwise than by reason of a failure or default under the terms or conditions of the share or any agreement that related to, and was entered into at the time of, the issuance of the share,
(iii)in respect of a share issued before November 17, 1978, at any particular time after November 16, 1978 the redemption date was extended or the terms or conditions relating to its redemption, acquisition, cancellation, conversion or reduction of its paid-up capital were changed,
(iv)at a particular time after October 23, 1979 and before November 13, 1981, a specified financial institution (or a partnership or trust of which a specified financial institution or a person related to the institution is a member or beneficiary) acquired a share that
(A)was issued before November 17, 1978 or under an established agreement,
(B)was issued to a person other than a corporation that was, at the time of issue,
(I)described in any of paragraphs (a) to (e) of the definitionspecified financial institution, or
(II)a corporation that was controlled by one or more corporations described in subclause (I) and, for the purpose of this subclause, one corporation is controlled by another corporation if more than 50% of its issued share capital (having full voting rights under all circumstances) belongs to the other corporation, to persons with whom the other corporation does not deal at arm’s length, or to the other corporation and persons with whom the other corporation does not deal at arm’s length,
(C)was acquired from a person that was, at the particular time, a person other than a corporation described in subclause (B)(I) or (II), and
(D)was acquired otherwise than under an agreement in writing made before October 24, 1979,
(v)at any particular time after November 12, 1981
(A)in respect of
(I)a share (other than a share referred to in paragraph (e) or a share listed on November 13, 1981 on a prescribed stock exchange in Canada) issued after November 16, 1978 and before November 13, 1981, or
(II)a share issued after November 12, 1981 and before 1983 pursuant to an agreement in writing to do so made before November 13, 1981 (in this definition referred to as a “specified agreement”)
the owner thereof could require, either alone or together with one or more taxpayers, the redemption, acquisition, cancellation, conversion or reduction of the paid-up capital of the share otherwise than by reason of a failure or default under the terms or conditions of the share or any agreement that related to, and was entered into at the time of, the issuance of the share, or
(B)the redemption date of
(I)a share issued after November 16, 1978 and before November 13, 1981 or
(II)a share issued pursuant to a specified agreement
was extended or the terms or conditions relating to its redemption, acquisition, cancellation, conversion or reduction of its paid-up capital were changed, or
(vi)at a particular time after November 12, 1981, a specified financial institution (or a partnership or trust of which a specified financial institution or a person related to the institution is a member or beneficiary) acquired a share (other than a share referred to in paragraph (e)) that
(A)was issued before November 13, 1981 or under a specified agreement,
(B)was acquired from a partnership or person, other than a person that was, at the particular time, a corporation described in any of paragraphs (a) to (f) of the definitionspecified financial institutionin this subsection,
(C)was acquired in an acquisition that was not subject to nor conditional on a guarantee agreement, within the meaning assigned by subsection 112(2.2), entered into after November 12, 1981, and
(D)was acquired otherwise than under an agreement in writing made before October 24, 1979 or a specified agreement,
the share shall, for the purposes of determining at any time after the particular time whether it is a term preferred share, be deemed to have been issued at the particular time otherwise than pursuant to an established or specified agreement,
(i)where the terms or conditions of a share of the capital stock of the issuing corporation are modified or established after June 28, 1982 and as a consequence thereof the issuing corporation, any person related thereto or any partnership or trust of which the issuing corporation or a person related thereto is a member or a beneficiary may reasonably be expected at any time to redeem, acquire or cancel, in whole or in part, the share or to reduce its paid-up capital, the share shall be deemed as from the date of the modification or as from the date of the establishment, as the case may be, to be a share described in paragraph (a),
(i.1)where
(i)it may reasonably be considered that the dividends that may be declared or paid at any time on a share (other than a prescribed share or a share described in paragraph (e) 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 term 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 subsection 112(2.1) or 138(6),
the share shall be deemed at that time to be a term preferred share acquired in the ordinary course of business,
(i.2)where at any particular time after December 15, 1987, otherwise than pursuant to a written arrangement to do so entered into before December 16, 1987, the terms or conditions of a taxable preferred share of the capital stock of a corporation relating to any matter referred to in subparagraphs (a)(i) to (iv) have been modified or established, or any agreement in respect of the share relating to any such matter has been changed or entered into by the corporation or a specified person (within the meaning assigned by paragraph (h) of the definitiontaxable preferred sharein this subsection) in relation to the corporation, the share shall be deemed after that particular time to have been issued at that particular time, and,
(j)where a particular share of the capital stock of a corporation has been issued or its terms and conditions have been modified and it may reasonably be considered, having regard to all circumstances (including the rate of interest on any debt or the dividend provided on any term preferred share), that
(i)but for the existence at any time of the debt or the term preferred share, the particular share would not have been issued or its terms or conditions modified, and
(ii)one of the main purposes for the issue of the particular share or for the modification of its terms or conditions was to avoid a limitation provided by subsection 112(2.1) or 138(6) in respect of a deduction,
the particular share shall be deemed after December 31, 1982 to be a term preferred share of the corporation; (action privilégiée à terme)
testamentary trusthas the meaning assigned by subsection 108(1); (fiducie testamentaire)
TFSA, being a tax-free savings account, has the meaning assigned by subsection 146.2(5); (compte d’épargne libre d’impôt)
timber resource propertyhas the meaning assigned by subsection 13(21); (avoir forestier)
total pension adjustment reversalof a taxpayer for a calendar year has the meaning assigned by regulation; (facteur d’équivalence rectifié total)
Treasury Boardmeans the Treasury Board established by section 5 of theFinancial Administration Act; (Conseil du Trésor)
treaty-protected businessof 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)
treaty-protected propertyof 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)
trusthas the meaning assigned by subsection 104(1) and, unless the context otherwise requires, includes an estate; (fiducie)
trust account numbermeans 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)
undepreciated capital costto a taxpayer of depreciable property of a prescribed class has the meaning assigned by subsection 13(21); (fraction non amortie du coût en capital)
unit trusthas the meaning assigned by subsection 108(2); (fiducie d’investissement à participation unitaire)
unused RRSP deduction roomof a taxpayer at the end of a taxation year has the meaning assigned by subsection 146(1); (déductions inutilisées au titre des REER)
unused scientific research and experimental development tax creditof 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)
unused share-purchase tax creditof 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)
zero-emission passenger vehicle, of a taxpayer, means an automobile of the taxpayer that is included in Class 54 of Schedule II to theIncome Tax Regulations; (voiture de tourisme zéro émission)
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 2028,
(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 theIncome 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 of the taxpayer if subsection 1104(4) of theIncome Tax Regulationswere read without its exclusions for property included in Class 54 or Class 55 of Schedule II to those Regulations. (véhicule zéro émission)
Marginal note:Non-disposition before December 24, 1998
(1.1)A redemption, an acquisition or a cancellation, at any particular time after 1971 and before December 24, 1998, of a share or of a right to acquire a share (which share or which right, as the case may be, is referred to in this subsection as the “security”) of the capital stock of a corporation (referred to in this subsection as the “issuing corporation”) held by another corporation (referred to in this subsection as the “disposing corporation”) is not a disposition (within the meaning of the definitiondispositionin section 54 as that section read in its application to transactions and events that occurred at the particular time) of the security if
(a)the redemption, acquisition or cancellation occurred as part of a merger or combination of two or more corporations (including the issuing corporation and the disposing corporation) to form one corporate entity (referred to in this subsection as the “new corporation”);
(b)the merger or combination
(i)is an amalgamation (within the meaning assigned by subsection 87(1) as it read at the particular time) to which subsection 87(11) if in force, and as it read, at the particular time did not apply,
(ii)is an amalgamation (within the meaning assigned by subsection 87(1) as it read at the particular time) to which subsection 87(11) if in force, and as it read, at the particular time applies, if the issuing corporation and the disposing corporation are described by subsection 87(11) (if in force, and as it read, at the particular time) as the parent and the subsidiary, respectively,
(iii)occurred before November 13, 1981 and is a merger of corporations that is described by subsection 87(8) (as it read in respect of the merger or combination), or
(iv)occurred after November 12, 1981 and
(A)is a foreign merger (within the meaning assigned by subsection 87(8.1) as it read in respect of the merger or combination), or
(B)all of the following conditions are met:
(I)the merger or combination is not a foreign merger (within the meaning assigned by subsection 87(8.1) as it read in respect of the merger or combination),
(II)subsection 87(8.1), as it read in respect of the merger or combination, contained a subparagraph (c)(ii), and
(III)the merger or combination would be a foreign merger (within the meaning of subsection 87(8.1), as it read in respect of the merger or combination) if that subparagraph 87(8.1)(c)(ii) were read as follows:
“(ii)if, immediately after the merger, the new foreign corporation was controlled by another foreign corporation (in this subsection referred to as the “parent corporation”), shares of the capital stock of the parent corporation,”;
and
(c)either
(i)the disposing corporation received no consideration for the security, or
(ii)in the case where the merger or combination is described by subparagraph (b)(iv), the disposing corporation received no consideration for the security other than property that was, immediately before the merger or combination, owned by the issuing corporation and that, on the merger or combination, became property of the new corporation.
Marginal note:Tax payable
(2)In this Act, the tax payable by a taxpayer under any Part of this Act by or under which provision is made for the assessment of tax means the tax payable by the taxpayer as fixed by assessment or reassessment subject to variation on objection or on appeal, if any, in accordance with the provisions of that Part.
Marginal note:Property subject to certain Quebec institutions and arrangements
(3)For the purposes of this Act, if property is subject to an institution or arrangement that is described by this subsection and that is governed by the laws of the Province of Quebec, the following rules apply in respect of the property:
(a)if at any time property is subject to a usufruct, right of use or habitation, or substitution,
(i)the usufruct, right of use or habitation, or substitution, as the case may be, is deemed to be at that time
(A)a trust, and
(B)where the usufruct, right of use or habitation, or substitution, as the case may be, is created by will, a trust created by will,
(ii)the property is deemed
(A)where the usufruct, right of use or habitation, or substitution, as the case may be, arises on the death of a testator, to have been transferred to the trust on and as a consequence of the death of the testator, and not otherwise, and
(B)where the usufruct, right of use or habitation, or substitution, as the case may be, arises otherwise, to have been transferred (at the time it first became subject to the usufruct, right of use or habitation, or substitution, as the case may be) to the trust by the person that granted the usufruct, right of use or habitation, or substitution, and
(iii)the property is deemed to be, throughout the period in which it is subject to the usufruct, right of use or habitation, or substitution, as the case may be, held by the trust, and not otherwise;
(b)an arrangement (other than a partnership, a qualifying arrangement or an arrangement that is a trust determined without reference to this paragraph) is deemed to be a trust and property subject to rights and obligations under the arrangement is, if the arrangement is deemed by this paragraph to be a trust, deemed to be held in trust and not otherwise, where the arrangement
(i)is established before October 31, 2003 by or under a written contract that
(A)is governed by the laws of the Province of Quebec, and
(B)provides that, for the purposes of this Act, the arrangement shall be considered to be a trust, and
(ii)creates rights and obligations that are substantially similar to the rights and obligations under a trust (determined without reference to this subsection);
(c)if the arrangement is a qualifying arrangement,
(i)the arrangement is deemed to be a trust,
(ii)any property contributed at any time to the arrangement by an annuitant, a holder or a subscriber of the arrangement, as the case may be, is deemed to have been transferred, at that time, to the trust by the contributor, and
(iii)property subject to rights and obligations under the arrangement is deemed to be held in trust and not otherwise;
(d)a person who has a right (whether immediate or future and whether absolute or contingent) to receive all or part of the income or capital in respect of property that is referred to in paragraph (a) or (b) is deemed to be beneficially interested in the trust; and
(e)notwithstanding that a property is at any time subject to a servitude, the property is deemed to be beneficially owned by a person at that time if, at that time, the person has in relation to the property
(i)the right of ownership,
(ii)a right as a lessee under an emphyteusis, or
(iii)a right as a beneficiary in a trust.
Marginal note:Gift of bare ownership of immovables
(3.1)Subsection (3) does not apply in respect of a usufruct or a right of use of an immovable in circumstances where a taxpayer disposes of the bare ownership of the immovable by way of a gift to a qualified donee and retains, for life, the usufruct or the right of use.
Marginal note:Qualifying arrangement
(3.2)For the purposes of paragraphs 248(3)(b) and (c), an arrangement is a qualifying arrangement if it is
(a)entered into with a corporation that is licensed or otherwise authorized under the laws of Canada or a province to carry on in Canada the business of offering to the public its services as trustee;
(b)established by or under a written contract that is governed by the laws of the Province of Quebec;
(c)presented as a declaration of trust or provides that, for the purposes of this Act, it shall be considered to be a trust; and
(d)presented as an arrangement in respect of which the corporation is to take action for the arrangement to become a registered disability savings plan, a registered education savings plan, a registered retirement income fund, a registered retirement savings plan or a TFSA.
Marginal note:Interest in real property
(4)In this Act, an interest in real property includes a leasehold interest in real property but does not include an interest as security only derived by virtue of a mortgage, agreement for sale or similar obligation.
Marginal note:Real right in immovables
(4.1)In this Act, a real right in an immovable includes a lease but does not include a security right derived by virtue of a hypothec, agreement for sale or similar obligation.
Marginal note:Substituted property
(5)For the purposes of this Act, other than paragraph 98(1)(a),
(a)where a person has disposed of or exchanged a particular property and acquired other property in substitution therefor and subsequently, by one or more further transactions, has effected one or more further substitutions, the property acquired by any such transaction shall be deemed to have been substituted for the particular property; and
(b)any share received as a stock dividend on another share of the capital stock of a corporation shall be deemed to be property substituted for that other share.
Marginal note:“Class” of shares issued in series
(6)In its application in relation to a corporation that has issued shares of a class of its capital stock in one or more series, a reference in this Act to the “class” shall be read, with such modifications as the circumstances require, as a reference to a “series of the class.”
Marginal note:Receipt of things mailed
(7)For the purposes of this Act,
(a)anything (other than a remittance or payment described in paragraph 248(7)(b)) sent by first class mail or its equivalent shall be deemed to have been received by the person to whom it was sent on the day it was mailed; and
(b)the remittance or payment of an amount
(i)deducted or withheld, or
(ii)payable by a corporation,
as required by this Act or a regulation shall be deemed to have been made on the day on which it is received by the Receiver General.
Marginal note:Occurrences as a consequence of death
(8)For the purpose of this Act,
(a)a transfer, distribution or acquisition of property under or as a consequence of the terms of the will or other testamentary instrument of a taxpayer or the taxpayer’s spouse or common-law partner or as a consequence of the law governing the intestacy of a taxpayer or the taxpayer’s spouse or common-law partner shall be considered to be a transfer, distribution or acquisition of the property as a consequence of the death of the taxpayer or the taxpayer’s spouse or common-law partner, as the case may be;
(b)a transfer, distribution or acquisition of property as a consequence of a disclaimer, release or surrender by a person who was a beneficiary under the will or other testamentary instrument or on the intestacy of a taxpayer or the taxpayer’s spouse or common-law partner shall be considered to be a transfer, distribution or acquisition of the property as a consequence of the death of the taxpayer or the taxpayer’s spouse or common-law partner, as the case may be; and
(c)a release or surrender by a beneficiary under the will or other testamentary instrument or on the intestacy of a taxpayer with respect to any property that was property of the taxpayer immediately before the taxpayer’s death shall be considered not to be a disposition of the property by the beneficiary.
Marginal note:Definitions
(9)In subsection 248(8),
disclaimerincludes 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)
release or surrendermeans
(a)a release or surrender made under the laws of a province (other than the Province of Quebec) that does not direct in any manner who is entitled to benefit therefrom, or
(b)a giftinter vivosmade under the laws of the Province of Quebec of an interest in, or right to property of, a succession that is made to the person or persons who would have benefited if the donor had made a renunciation of the succession that was not made in favour of any person,
and that is made within the period ending 36 months after the death of the taxpayer or, where written application therefor has been made to the Minister by the taxpayer’s legal representative within that period, within such longer period as the Minister considers reasonable in the circumstances. (abandon)
Marginal note:How trust created
(9.1)For the purposes of this Act, a trust shall be considered to be created by a taxpayer’s will if the trust is created
(a)under the terms of the taxpayer’s will; or
(b)by an order of a court in relation to the taxpayer’s estate made under any law of a province that provides for the relief or support of dependants.
Marginal note:Vested indefeasibly
(9.2)For the purposes of this Act, property shall be deemed not to have vested indefeasibly
(a)in a trust under which a taxpayer’s spouse or common-law partner is a beneficiary, where the trust is created by the will of the taxpayer, unless the property vested indefeasibly in the trust before the death of the spouse or common-law partner; and
(b)in an individual (other than a trust), unless the property vested indefeasibly in the individual before the death of the individual.
Marginal note:Series of transactions
(10)For the purposes of this Act, where there is a reference to a series of transactions or events, the series shall be deemed to include any related transactions or events completed in contemplation of the series.
Marginal note:Compound interest
(11)Interest computed at a prescribed rate under any of subsections 129(2.1) and (2.2), 131(3.1) and (3.2), 132(2.1) and (2.2), 133(7.01) and (7.02), 159(7), 160.1(1), 161(1), (2) and (11), 161.1(5), 164(3) to (4), 181.8(1) and (2) (as those two subsections read in their application to the 1991 and earlier taxation years), 185(2), 187(2) and 189(7), section 190.23 (as it read in its application to the 1991 and earlier taxation years) and subsections 193(3), 195(3), 202(5) and 227(8.3), (9.2) and (9.3) of this Act and subsection 182(2) of theIncome Tax Act, chapter 148 of the Revised Statutes of Canada, 1952 (as that subsection read in its application to taxation years beginning before 1986) and subsection 191(2) of that Act (as that subsection read in its application to the 1984 and earlier taxation years) shall be compounded daily and, where interest is computed on an amount under any of those provisions and is unpaid or unapplied on the day it would, but for this subsection, have ceased to be computed under that provision, interest at the prescribed rate shall be computed and compounded daily on the unpaid or unapplied interest from that day to the day it is paid or applied and shall be paid or applied as would be the case if interest had continued to be computed under that provision after that day.
Marginal note:Identical properties
(12)For the purposes of this Act, one bond, debenture, bill, note or similar obligation issued by a debtor is identical to another such obligation issued by that debtor if both are identical in respect of all rights (in equity or otherwise, either immediately or in the future and either absolutely or contingently) attaching thereto, except as regards the principal amount thereof.
Marginal note:Interests in trusts and partnerships
(13)Where after November 12, 1981 a person has an interest in a trust or partnership, whether directly or indirectly through an interest in any other trust or partnership or in any manner whatever, the person shall, for the purposes of the definitionsincome bond,income debentureandterm preferred sharein subsection 248(1), paragraph (h) of the definitiontaxable preferred sharein that subsection, subsections 84(4.2) and 84(4.3) and 112(2.6) and section 258, be deemed to be a beneficiary of the trust or a member of the partnership, as the case may be.
Marginal note:Related corporations
(14)For the purpose of paragraph (g) of the definitionspecified financial institutionin subsection 248(1), where in the case of 2 or more corporations it can reasonably be considered, having regard to all the circumstances, that one of the main reasons for the separate existence of those corporations in a taxation year is to limit or avoid the application of subsection 112(2.1) or 112(2.2) or 138(6), the 2 or more corporations shall be deemed to be related to each other and to each other corporation to which any such corporation is related.
Marginal note:Goods and services tax — change of use
(15)For the purposes of this Act, where a liability for the goods and services tax is incurred in respect of a change of use at any time of a property, the liability so incurred shall be deemed to have been incurred immediately after that time in respect of the acquisition of the property.
Marginal note:Goods and services tax — input tax credit and rebate
(16)For the purposes of this Act, other than this subsection and subsection 6(8), an amount claimed by a taxpayer as an input tax credit or rebate with respect to the goods and services tax in respect of a property or service is deemed to be assistance from a government in respect of the property or service that is received by the taxpayer
(a)where the amount was claimed by the taxpayer as an input tax credit in a return under Part IX of theExcise Tax Actfor a reporting period under that Act,
(i)at the particular time that is the earlier of the time that the goods and services tax in respect of the input tax credit was paid and the time that it became payable,
(A)if the particular time is in the reporting period, or
(B)if,
(I)the taxpayer’s threshold amount, determined in accordance with subsection 249(1) of theExcise Tax Act, is greater than $500,000 for the taxpayer’s fiscal year (within the meaning assigned by that Act) that includes the particular time, and
(II)the taxpayer claimed the input tax credit at least 120 days before the end of the normal reassessment period, as determined under subsection 152(3.1), for the taxpayer in respect of the taxation year that includes the particular time,
(ii)at the end of the reporting period, if
(A)subparagraph (i) does not apply, and
(B)the taxpayer’s threshold amount, determined in accordance with subsection 249(1) of theExcise Tax Act, is $500,000 or less for the fiscal year (within the meaning assigned by that Act) of the taxpayer that includes the particular time, and
(iii)in any other case, on the last day of the taxpayer’s earliest taxation year
(A)that begins after the taxation year that includes the particular time, and
(B)for which the normal reassessment period, as determined under subsection 152(3.1), for the taxpayer ends at least 120 days after the time that the input tax credit was claimed; or
(b)where the amount was claimed as a rebate with respect to the goods and services tax, at the time the amount was received or credited.
Marginal note:Quebec input tax refund and rebate
(16.1)For the purpose of this Act, other than this subsection and subsection 6(8), an amount claimed by a taxpayer as an input tax refund or a rebate with respect to the Quebec sales tax in respect of a property or service is deemed to be assistance from a government in respect of the property or service that is received by the taxpayer
(a)where the amount was claimed by the taxpayer as an input tax refund in a return underAn Act respecting the Québec sales tax, R.S.Q., c