Cases
Allendale Mutual Insurance Co. v. The Queen, 73 DTC 5382, [1973] CTC 494 (FCTD)
Policy holders, who were members of factory mutual companies, were not entitled to dividends as such, and accordingly were not shareholders.
Administrative Policy
2 December 2014 Folio S4-F7-C1
1.7 Subsection 248(1) defines a shareholder to include a member or other person entitled to receive a dividend. Therefore, a person can be a shareholder of a corporation even if that person does not own any shares of the corporation. An example would be a policyholder of a mutual insurance corporation. The fact that such a shareholder does not receive any shares of the new corporation because of the amalgamation will not cause the requirement described in [s. 87(1)(c)] not to have been met.
7 November 2013 T.I. 2013-0473771E5 - Shareholder of a Not-for-profit corporation
In response to a detailed submission to the contrary, CRA maintained its position under the expanded definition of "shareholder"
that members of a non-profit corporation without share capital will be considered shareholders thereof for purposes of subsection 15(1) of the Act, notwithstanding that they are not entitled to receive dividends.