Income Tax Act — I-3.3 212.3
ns or events that includes the making of the investment occurs and that are before the investment time, controlled by the group of parents; (b) the investment is described in paragraph (10)(a) and is an acquisition of shares of the capital stock of the subject corporation in which the shares are acquired by the CRIC (i) in an exchange to which subsection 51(1) applies, (ii) as consideration for a disposition of shares to which subsection 85.1(3) applies (determined without reference to subsection 85.1(4)), (iii) in the course of a reorganization of the capital of the subject corporation to which subsection 86(1) applies, (iv) as a result of a foreign merger (as defined in subsection 87(8.1)) under which the subject corporation was formed, (v) on a liquidation and dissolution to which subsection 88(3) applies, (vi) on a redemption of shares of another non-resident corporation that is, immediately before the investment time, a foreign affiliate of the CRIC, (vii) as a dividend or a qualifying return of capital, within the meaning assigned by subsection 90(3), in respect of the shares of another non-resident corporation that is, immediately before the investment time, a foreign affiliate of the CRIC, or (viii) as a result of a disposition of the shares by the CRIC to a partnership and to which subsection 97(2) applies; (c) the investment is an indirect acquisition referred to in paragraph (10)(f) that results from a direct acquisition of shares of the capital stock of another corporation resident in Canada (i) from a corporation (in this paragraph referred to as the “disposing corporation”) to which the CRIC is, immediately before the investment time, related (determined without reference to paragraph 251(5)(b)) and (A) each shareholder of the disposing corporation immediately before the investment time is (I) if there is only one parent in respect of the CRIC, 1 either the CRIC or a corporation resident in Canada that, immediately before the investment time, is related to the parent, and 2 at no time that is in the period during which the series of transactions or events that includes the making of the investment occurs and that is before the investment time, dealing at arm’s length (determined without reference to paragraph 251(5)(b)) with the parent or a non-resident person that participates in the series and is, at any time that is in the period and that is before the investment time, related to the parent, and (II) if there is a group of parents in respect of the CRIC, 1 either the CRIC or a corporation resident in Canada that is, immediately before the investment time, controlled by the group of parents, and 2 at all times that are in the period during which the series of transactions or events that includes the making of the investment occurs and that are before the investment time, controlled by the group of parents, or (B) the disposing corporation is (I) if there is only one parent in respect of the CRIC, at no time that is in the period and that is before the investment time, dealing at arm’s length (determined without reference to paragraph 251(5)(b)) with the parent or a non-resident person that participates in the series and is, at any time that is in the period and that is before the investment time, related to the parent, and (II) if there is a group of parents in respect of the CRIC, at all times that are in the period during which the series of transactions or events that includes the making of the investment occurs and that are before the investment time, controlled by the group of parents, or (ii) on an amalgamation described in subsection 87(1) of two or more corporations (each of which is in this subparagraph referred to as a “predecessor corporation”) to form the CRIC, or a corporation of which the CRIC is a shareholder, if all of the predecessor corporations are, immediately before the amalgamation, related to each other (determined without reference to paragraph 251(5)(b)) and (A) either (I) if there is o