The Charger, AvenEx and Pace amalgamation will qualify as a tax-deferred exchange under Code s. 368(a).

Three oil and gas companies (Charger, AvenEx and Pace) amalgamated under a plan of arrangement.  Rather than this occurring directly, there was an exchange under s. 85.1 of shares of two of the companies (Charger and AvenEx) for shares of the third (Pace), followed by the amalgamation.  This qualifies as a tax-deferred exchange under Code s. 368(a).

Avoiding a single amalgamation avoided an acquisition of control of Pace that otherwise would have occurred under s. 256(7)(b) (and s. 256(7)(c) did not apply on the successive share-for-share exchanges).

As the last step, the stated capital of the shares of Amalco was reduced to a nominal amount, with such reduction added to contributed surplus (presumably with a view to the reduction being reversed later under s. 84(1)(c.3) if the occasion should arise.)

Neal Armstrong.  Summary of Charger, AvenEx and Pace Circular under Amalgamations.