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Regarding the first point, she noted that the redemption amount was not required by s. 181(5) to be paid “exclusively” or “primarily” in the course of a commercial activity, and stated (at para. 26): Unlike the words exclusively and primarily, the phrase “in the course of” has a broad meaning; it means “incidental to” or “connected to” directly or indirectly …. ...

., acquiring the FMO units at a high cost in steps 2 and 4, being allocated a capital gain by FMO in step 6 so as to generate a CDA increase which could then be distributed, and having their high cost FMO units redeemed in Step 7 so as to generate a capital loss to offset the capital gain in step 6) and “the only purpose for the appellants’ participation in the series of transactions was to pay capital dividends to their parent corporations and to avoid Part III tax in doing so” (para. 202) – and there accordingly was an avoidance transaction. ...