Although s. 256(6)(a) was satisfied, s. 256(6)(b) was not satisfied regarding the shareholding of Holdco1 in Opco1. Although CCRA accepted that one of the reasons for Holdco1 controlling Opco1 was to safeguard its rights with respect to the shares it owned and which Opco1 was to purchase for cancellation based on Opco1’s financial performance, Holdco1 also wanted such control in order to indirectly protect its investment in a building that it had leased to Opco1 for use in Opco1’s business.