Full text
the amount determined by the formula A × B/C where A is the amount, if any, by which the proceeds of disposition of the transferor of the transferred property determined under paragraph 138(11.5)(e) exceed the fair market value, at that time, of the consideration (other than shares of the capital stock of the transferee or a right to receive any such shares) received or receivable by the transferor for the transferred property, B is the fair market value, immediately after the transfer of the transferred property, of those preferred shares of that class, and C is the fair market value, immediately after the transfer of the transferred property, of all preferred shares of the capital stock of the transferee receivable by the transferor as consideration for the transferred property, and