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the new shares (or shares for which the new shares are substituted property) were
the new shares (or shares for which the new shares are substituted property) were
the new shares (or shares for which the new shares are substituted property) were issued by the corporation that issued the old shares or were issued by a corporation that, at or immediately after the time of issue of those shares, was a corporation that was not dealing at arm’s length with the corporation that issued the old shares; and