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the cost to the disposing affiliate of each share of a class of the capital stock of the acquiring affiliate that is receivable by the disposing affiliate as consideration for the disposition is deemed to be the amount determined by the formula(A – B) × C/D where A is the total of all amounts each of which is the relevant cost base to the disposing affiliate at that time, in respect of the taxpayer, of a share disposed of, B is the fair market value at that time of the consideration receivable for the disposition (other than shares of the capital stock of the acquiring affiliate), C is the fair market value, immediately after that time, of the share, and D is the fair market value, immediately after that time, of all shares of the capital stock of the acquiring affiliate receivable by the disposing affiliate as consideration for the disposition,