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paid by a particular corporation that would, but for paragraphs (h) and (i) of the definition financial intermediary corporation in this subsection, have been a financial intermediary corporation at the time the dividend was paid, except where the dividend was paid to a controlling corporation in respect of the particular corporation or to a specified person (within the meaning assigned by paragraph (h) of the definition taxable preferred share in subsection 248(1)) in relation to such a controlling corporation,