Income Tax Act — I-3.3 55
 a significant increase in the total direct interest in a corporation that would, but for this paragraph, be described in subparagraph (3)(a)(ii), is deemed not to be described in those subparagraphs if (i) the dividend payer was related to the dividend recipient immediately before the dividend was received, (ii) the dividend payer did not, as part of the series of transactions or events that includes the receipt of the dividend, cease to be related to the dividend recipient, (iii) the disposition or increase occurred before the dividend was received, (iv) the disposition or increase was the result of the disposition of shares to, or the acquisition of shares of, a particular corporation, and (v) at the time the dividend was received, all the shares of the capital stock of the dividend recipient and the dividend payer were owned by the particular corporation, a corporation that controlled the particular corporation, a corporation controlled by the particular corporation or any combination of those corporations; and (h) a winding-up of a subsidiary wholly-owned corporation to which subsection 88(1) applies, or an amalgamation to which subsection 87(11) applies of a corporation with one or more subsidiary wholly-owned corporations, is deemed not to result in a significant increase in the total direct interest, or in the total of all direct interests, in the subsidiary or subsidiaries, as the case may be. Distribution by a specified corporation (3.02) For the purposes of the definition distribution in subsection (1), where the transfer referred to in that definition is by a specified corporation to an acquiror described in the definition specified corporation in subsection (1), the references in the definition distribution to (a) “each type of property” shall be read as “property”; and (b) “property of that type” shall be read as “property”. Where paragraph (3)(b) not applicable (3.1) Notwithstanding subsection 55(3), a dividend to which subsection 55(2) would, but for paragraph 55(3)(b), apply is not excluded from the application of subsection 55(2) where (a) in contemplation of and before a distribution (other than a distribution by a specified corporation) made in the course of the reorganization in which the dividend was received, property became property of the distributing corporation, a corporation controlled by it or a predecessor corporation of any such corporation otherwise than as a result of (i) an amalgamation of corporations each of which was related to the distributing corporation, (ii) an amalgamation of a predecessor corporation of the distributing corporation and one or more corporations controlled by that predecessor corporation, (iii) a reorganization in which a dividend was received to which subsection 55(2) would, but for paragraph 55(3)(b), apply, or (iv) a disposition of property by (A) the distributing corporation, a corporation controlled by it or a predecessor corporation of any such corporation to a corporation controlled by the distributing corporation or a predecessor corporation of the distributing corporation, (B) a corporation controlled by the distributing corporation or by a predecessor corporation of the distributing corporation to the distributing corporation or predecessor corporation, as the case may be, or (C) the distributing corporation, a corporation controlled by it or a predecessor corporation of any such corporation for consideration that consists only of money or indebtedness that is not convertible into other property, or of any combination thereof, (b) the dividend was received as part of a series of transactions or events in which (i) a person or partnership (referred to in this subparagraph as the “vendor”) disposed of property and (A) the property is (I) a share of the capital stock of a distributing corporation that made a distribution as part of the series or of a transferee corporation in relation to the distributing corporation, or (II) property 10% or more of the fair marke