3 November 89 T.I. (April 90 Access Letter, ¶1172)

"A preliminary transaction will form part of the series of transactions or events determined with reference to subsection 248(10) if, at the time that the preliminary transaction is carried out, the taxpayer is intending to implement the subsequent transactions constituting the series, and the subsequent transactions are eventually carried out. Thus, the preliminary and subsequent transactions will be part of the series even though at the time of completing the preliminary transactions the taxpayer either had not determined all the important elements of the subsequent transactions - such as, for instance, the identity of the other taxpayers involved - or lacked the ability to implement the subsequent transactions."

A U.S. corporation has a wholly-owned Canadian operating subsidiary ("Subco 1") and a newly incorporated wholly-owned Canadian subsidiary ("Subco 2"). Part of the business of Subco 1 is transferred to Subco 2 for business reasons and a deemed dividend is received in the course of the reorganization. If the shares of Subco 2 are sold to an arm's length buyer in a transaction that was not part of the original series of transactions, then the fact that the subsequent sale would not have occurred if the reorganization had not taken place does not establish a sufficient causal connection to say that the restructuring "resulted in" the sale. However, if one of the purposes of the restructuring was to make the business division of Subco 1 that was transferred to Subco 2 saleable to potential buyers, then RC likely would consider the restructuring and the ultimate sale to form part of the same series of transactions or events.