Income Tax Act — I-3.3 88
 person to be a specified person so as to prevent a property that is distributed to the parent on the winding-up from being an ineligible property for the purposes of paragraph (c), (ii) where at any time a property is owned or acquired by a partnership or a trust, (A) the partnership or the trust, as the case may be, shall be deemed to be a person that is a corporation having one class of issued shares, which shares have full voting rights under all circumstances, (B) each member of the partnership or beneficiary under the trust, as the case may be, shall be deemed to own at that time the proportion of the number of issued shares of the capital stock of the corporation that (I) the fair market value at that time of that member’s interest in the partnership or that beneficiary’s interest in the trust, as the case may be, is of (II) the fair market value at that time of all the members’ interests in the partnership or beneficiaries’ interests in the trust, as the case may be, and (C) the property shall be deemed to have been owned or acquired at that time by the corporation, (iii) in determining whether a person is a specified shareholder of a corporation, (A) the reference in the definition specified shareholder in subsection 248(1) to “the issued shares of any class of the capital stock of the corporation or of any other corporation that is related to the corporation” shall be read as “the issued shares of any class (other than a specified class) of the capital stock of the corporation or of any other corporation that is related to the corporation and that has a significant direct or indirect interest in any issued shares of the capital stock of the corporation”, (A.1) a corporation controlled by another corporation is, at any time, deemed not to own any shares of the capital stock of the other corporation if, at that time, the corporation does not have a direct or an indirect interest in any of the shares of the capital stock of the other corporation, (A.2) the definition specified shareholder in subsection 248(1) is to be read without reference to its paragraph (a) in respect of any share of the capital stock of the subsidiary that the person would, but for this clause, be deemed to own solely because the person has a right described in paragraph 251(5)(b) to acquire shares of the capital stock of a corporation that (I) is controlled by the subsidiary, and (II) does not have a direct or an indirect interest in any of the shares of the capital stock of the subsidiary, and (B) a corporation is deemed not to be a specified shareholder of itself, and (iv) property that is distributed to the parent on the winding-up is deemed not to be acquired by a person if the person acquired the property before the acquisition of control referred to in clause (c)(vi)(A) and the property is not owned by the person at any time after that acquisition of control; (c.3) for the purpose of clause 88(1)(c)(vi)(B), property acquired by any person in substitution for particular property or properties distributed to the parent on the winding-up includes (i) property (other than a specified property) owned by the person at any time after the acquisition of control referred to in clause (c)(vi)(A) more than 10% of the fair market value of which is, at that time, attributable to the particular property or properties, and (ii) property owned by the person at any time after the acquisition of control referred to in clause 88(1)(c)(vi)(A) the fair market value of which is, at that time, determinable primarily by reference to the fair market value of, or to any proceeds from a disposition of, the particular property or properties but does not include (iii) money, (iv) property that was not owned by the person at any time after the acquisition of control referred to in clause 88(1)(c)(vi)(A), (v) property described in subparagraph 88(1)(c.3)(i) if the only reason the property is described in that subparagraph is because a specified property described in any o