If your shareholders don’t know about this transaction, then they’re not part of the series?

Where a grandchild Canadian subsidiary (Cco) of Pubco (a non-resident public corporation deriving more than 10% of its fair market value from Cco) redeems pref shares held by another Canadian subsidiary, on a literal reading of s. 55(3)(a)(iii) the resulting deemed dividend could be converted into a capital gain under s. 55(2) if trading in the shares of Pubco occurred as part of the same series of transactions.  In connection with getting a s. 55(3)(a) ruling, representations were made that there is no reason to believe that any Pubco shareholder is aware of these transactions (in addition to the ruling effectively being vitiated by a representation that none of the transactions described in s. 55(3)(a) would occur).  Sounds fair: a meaningless ruling is given in exchange for a rep that could never be proven.

Neal Armstrong.  Summary of  2013 Ruling 2013-0501811R3 under s. 55(3)(a).