Income Tax Act — I-3.3 183.3
 receives consideration that includes equity (other than substantive debt) of the new corporation (within the meaning of subsection 87(1)) for the disposition of their equity on the amalgamation; (b.1) on an amalgamation (as defined in subsection 87(1)) to which subsection 87(11) applies; (c) on a winding-up (i) of the covered entity during which all or substantially all of the property owned by the covered entity is distributed to the equity holders of the covered entity, or (ii) to which subsection 88(1) applies; (d) in the course of a reorganization to which paragraph 55(3)(a) or (b) applies; (e) on a qualifying disposition (as defined in subsection 107.4(1)); (f) on a qualifying exchange (as defined in subsection 132.2(1)); (g) at the demand of a holder in accordance with the conditions referred to in paragraph 108(2)(a), included in the issued units of the trust, for an amount that does not exceed the fair market value of the equity at the time of the redemption, acquisition or cancellation; (g.1) at the demand of a holder of the equity, in accordance with the conditions of the issued units of the trust, for an amount that does not exceed the portion of the net asset value (as defined in subsection 132(4)) of the trust attributable to that equity at the time of the redemption, acquisition or cancellation, if the covered entity is a trust that has one or more classes of units in continuous distribution; or (h) pursuant to the exercise of a statutory right of dissent by a holder of the equity. ( opération de réorganisation ) specified affiliate at any time, of a covered entity, means a corporation, trust or partnership (in this definition referred to as an “affiliate”) where, at that time, (a) if the affiliate is a corporation, the covered entity (i) controls the corporation, or (ii) has a direct or indirect interest in the equity of the corporation having a fair market value equal to more than 50% of the fair market value of the total equity of the corporation; (b) if the affiliate is a trust, the covered entity (i) is a majority-interest beneficiary (as defined in subsection 251.1(3)) of the trust, or (ii) has a direct or indirect interest in the equity of the trust having a fair market value equal to more than 50% of the fair market value of the total equity of the trust; and (c) if the affiliate is a partnership, the covered entity (i) is a majority-interest partner of the partnership, or (ii) has a direct or indirect interest in the equity of the partnership having a fair market value equal to more than 50% of the fair market value of the total equity of the partnership. ( entité affiliée déterminée ) substantive debt of a covered entity means equity that, in accordance with its terms (a) is not convertible or exchangeable other than for (i) equity that if issued would be substantive debt of the same covered entity, (ii) a bond, debenture or note of the covered entity, the fair market value of which does not exceed the total of the amounts referred to in subparagraphs (d)(i) to (iv), or (iii) equity that would be issued only after the occurrence of a trigger event pursuant to a non-viability contingent capital provision included in the terms of the equity to satisfy regulatory capital requirements applicable to the covered entity; (b) is non-voting in respect of the election of the board of directors, the trustees or the general partner (as applicable) of the covered entity, except in the event of a failure or default under the terms or conditions of the equity; (c) requires the amount of any dividend or other distribution payable to be calculated (i) as a fixed amount, or (ii) by reference to a percentage of an amount equal to the fair market value of the consideration for which the equity was issued if the percentage is (A) fixed, or (B) determined by reference to a market interest rate (including a Government of Canada Treasury Bill) plus a fixed amount, if any; and (d) entitles any holder of the equity to receive,