19 January 2005 External T.I. 2004-0081001E5 F - Réserve de valorisation d'une coopérative -- summary under Paragraph 181.2(3)(b)

S. 149.1 of the Quebec Cooperatives Act provided that certain cooperatives could set up an “enhancement reserve” to value the use of the cooperative's services. CRA indicated that “an amount credited by a cooperative as an enhancement reserve would constitute a reserve for the purposes of Part I.3.”