Subsection 55(4)

s. 55(4) inapplicable where parent retained de jure control primarily for protection of their economic interest

s. 55(4) inapplicable where parent retains control for the protection of parent’s economic interests

spinoff of a portion of portfolio of DC (controlled by father) to father-controlled TCs for the children

use of special voting shares by father questioned where most of the economic interest in the split-up business goes to the children

potential application of s. 55(4) where increase of interest of siblings companies is sheltered by control of Father – unless he held his shares to protect his “economic interests”

Parent reps that he will control the TCs for commercial reasons

s. 55(4) not engaged where transactions eliminate shareholdings but not unrelated status of unrelated person

s. 55(3)(a) split-up between Newcos for two siblings which were related due to multiple-voting shares held by the father’s and mother’s Holdco

s. 55(4) inapplicable if the principal reason for parent’s control of DC was parent's economic interests