Whether there is a “liquidation and dissolution” for QLAD or DLAD purposes likely turns on whether in substance there is a net asset distribution followed by corporate termination
The ITA definitions of qualifying liquidation and dissolution and a designated liquidation and dissolution both reference the undefined concept of “liquidation and dissolution.”
It is suggested that Canadian legal practitioners regard "liquidation" as generally referring to the “factual process of satisfying a corporation's creditors and distributing its remaining assets to its shareholders,” and "dissolution" as generally referring “to the acceptance by the relevant corporate registrar of the corporation's articles of dissolution, which terminates the corporation's legal existence.” Similarly:
What appears to be important in determining whether a corporation has been "liquidated" or "wound-up" is the broad substance of what occurred: Was there a realization of the corporation's assets (if any), a discharge of its liabilities (if any), and a distribution of its surplus (if any) to its shareholders?
CRA seemed to agree in 2003-0034311E5, i.e., it seemed to consider that it is the substance of what occurred (as opposed to the form) that is important in determining whether there is a “liquidation and dissolution”.
Neal Armstrong. Summary of Michael Kandev and Olivia Khazam, “Was there a ‘Liquidation and Dissolution’? A (Corporate) Existential Question,” International Tax (Wolters Kluwer CCH), No. 118, June 2021, pp. 8-9 under s. 88(3.1).