Richler, "Triangular Amalgamations", March/April 1985 Canadian Tax Journal, p. 374

RC accepts that where on a triangular amalgamation, those who controlled the target corporation control the parent following the amalgamation, there is no acquisition of control of the target.

RC has been willing to accommodate transactions whereby option holders and debenture holders of a predecessor corporation in effect receive options or debentures of the parent on a rollover basis, but it has been unwilling to accede to arguments that the "new shares" referred to in s. 87(9)(c) refer only to the shares of Amalco received by the parent in exchange for its previous shareholding in a predecessor.