We suggest a possible structure where the interest income on certificates of deposit issued by new banks up to a certain size in shareholders' equity receive some limited income tax relief.

(b) in any other province, if real property or any interest relating to it is the object of litigation under sections 91 to 99 of the Act, issue a certificate of lis pendens after a copy of the statement of claim signed by the plaintiff’s barrister or solicitor is filed with the court, and, if the plaintiff is unsuccessful in whole or in part, issue a certificate of disallowance.

(e) any bond, debenture, note or other evidence of indebtedness, share, stock, unit, unit certificate, participation certificate, certificate of share or interest, preorganization certificate or subscription other than a contract of insurance issued by an insurance company or a fraternal benefit society incorporated or formed under the Insurance Companies Act or an insurance corporation incorporated by or under an Act of the legislature of a province, and an evidence of deposit issued by a bank, by an association to which the Cooperative Credit Associations Act applies, a central cooperative credit society for which an order has been mad ...[+++]e under subsection 473(1) of that Act or a cooperative credit society incorporated and regulated by or under an Act of the legislature of a province or by a body corporate to which the Trust and Loan Companies Act applies or a trust or loan corporation incorporated by or under an Act of the legislature of a province; (f) any agreement under which the interest of the purchaser is valued for purposes of conversion or surrender by reference to the value of a proportionate interest in a specified portfolio of assets, except a contract issued by an insurance company or a fraternal benefit society incorporated or formed under the Insurance Companies Act or an insurance corporation incorporated by or under an Act of the legislature of a province, which provides for payment at maturity of an amount not less than three quarters of the premiums paid by the purchaser for a benefit payable at maturity; (g) any agreement providing that money received will be repaid or treated as a subscription to shares, stock, units or interests at the option of the recipient or of any person or company; (h) any certificate of share or interest in a trust, estate or association; (i) any profit-sharing agreement or certificate;

For tax purposes, dividends paid by financial cooperatives and interest paid on deposits are both — up to a fixed amount — exempted from withholding tax (47).

‘funds’ means financial assets and economic benefits of every kind, including but not limited to cash, cheques, claims on money, drafts, money orders and other payment instruments; deposits with financial institutions or other entities, balances on accounts, debts and debt obligations; publicly and privately traded securities and debt instruments, including stocks and shares, certificates presenting securities, bonds, notes, warrants, debentures, derivatives contracts; interest, dividends or other income on or value accruing from or generated by assets; credit, right of set-off, guarantees, performance bonds or other financial commit ...[+++]ments; letters of credit, bills of lading, bills of sale; documents evidencing an interest in funds or financial resources, and any other instrument of export-financing.