Is the reference to "all of the shares" in s. 88(1)(c)(vi)(B)(II) a reference only to shares of a subsidiary that is subsequently wound-up into its parent? CRA responded, "no:"
The reference to "all of the shares" in subclause 88(1)(c)(vi)(B)(II) is a reference to any shares owned by a person who acquires property distributed to the parent on the winding-up. The hypothetical person will be considered to be a specified shareholder of the subsidiary if it holds 10% or more of the issued shares of the subsidiary or of any other corporation that is related to the subsidiary and that has a significant interest in the issued shares of the subsidiary after applying the various presumptions in paragraphs (a) to (e) of that definition.