Income Tax Act — I-3.3 212.3
 capital stock of the subject corporation or the portion, of a reduction of paid-up capital or dividend in respect of a class of shares of the capital stock of a foreign affiliate of the particular corporation that were substituted for shares of the capital stock of the subject corporation, that can reasonably be considered to relate to shares of the capital stock of the subject corporation, or (III) if the investment is described in paragraph (10)(c) or (d) or subparagraph (10)(e)(i), 1 as a repayment of or as proceeds from the disposition of the debt obligation or amount owing, or 2 as interest on the debt obligation or amount owing, and (B) is not received by the recipient corporation (I) as a result of an investment, made by the recipient corporation, to which subsection (16) or (18) applies, or (II) as proceeds from a disposition of property to a corporation resident in Canada for which the acquisition is an investment to which subsection (16) or (18) applies, or to a partnership of which such a corporation is a member, B is the amount determined under paragraph (a) in respect of the class, and C is the total of all amounts each of which is an amount determined under paragraph (a) in respect of all classes of shares of the capital stock of the particular corporation or of any corporation that does not deal at arm’s length with the particular corporation. Exchange of debt obligation for shares (9.1) For the purposes of subsection (9), if at any time a debt obligation that relates to a particular investment described in paragraph (10)(c) or (d) or subparagraph (10)(e)(i) is exchanged for shares of a subject corporation and as part of the exchange there is an acquisition of shares described in subparagraph (18)(b)(i) or paragraph 18(d), then all amounts, in respect of the particular investment, deducted under paragraph (2)(b) or subsection (7) from, or added under subsection (9) to, the paid-up capital in respect of a class of shares before that time are deemed to have been deducted or added, as the case may be, in respect of the acquisition of the shares and not the particular investment. Continuity for paid-up capital reinstatement (9.2) If at any particular time shares (in this subsection referred to as the “new shares”) of a class of the capital stock of a corporation resident in Canada are acquired, in a transaction to which any of sections 51, 85, 85.1, 86 and 87 apply, in exchange for a share (in this subsection referred to as the “old share”) of a class of the capital stock of a particular corporation that is either the corporation or another corporation resident in Canada, then for the purposes of subsections (8) and (9), (a) if the corporation that issues the new shares is not the particular corporation, it is deemed to be the same corporation as, and a continuation of, the particular corporation; (b) the new shares are deemed to be the same share, and of the same class of the capital stock of the particular corporation, as the old share; and (c) if the old share remains outstanding after the exchange, it is deemed to be a share of a different class of the capital stock of the particular corporation. Investment in subject corporation (10) In this section, investment , in a subject corporation made by a CRIC, means any of (a) an acquisition of shares of the capital stock of the subject corporation by the CRIC; (b) a contribution of capital to the subject corporation by the CRIC, which is deemed to include any transaction or event under which a benefit is conferred on the subject corporation by the CRIC; (c) a transaction under which an amount becomes owing by the subject corporation to the CRIC, other than an amount owing (i) that arises in the ordinary course of the business of the CRIC and that is repaid, other than as part of a series of loans or other transactions and repayments, within 180 days after the day on which the amount becomes owing, (ii) that is a pertinent loan or indebtedness immediately after the t