Eastern Daylight Saving Time, June 18, 1987, the share shall be deemed to have been issued at the particular time and the guarantee agreement shall be deemed to have been given as part of a series of transactions that included the issuance of the share,
(A)fixed,(B)limited to a maximum, or(C)established to be not less than a minimum (including any amount determined on a cumulative basis) and with respect to the dividend that may be declared or paid on the share there is a preference over any other dividend that may be declared or paid on any other share of the capital stock of the corporation,
(A)fixed,(B)limited to a maximum, or(C)established to be not less than a minimum,
(A)it is convertible into or exchangeable for(I)another share of the corporation or a corporation related to the corporation that, if issued, would not be a taxable preferred share,(II)a right or warrant that, if exercised, would allow the person exercising it to acquire only a share of the corporation or a corporation related to the corporation that, if issued, would not be a taxable preferred share, or(III)both a share described in subclause (I) and a right or warrant described in subclause (II), and(B)all the consideration receivable for the share on the conversion or exchange is the share described in subclause (I) or the right or warrant described in subclause (II) or both, as the case may be, and, for the purposes of this clause, where a taxpayer may become entitled on the conversion or exchange of a share to receive any particular consideration (other than consideration described in any of subclauses (I) to (III)) in lieu of a fraction of a share, the particular consideration shall be deemed not to be consideration unless it may reasonably be considered that the particular consideration was receivable as part of a series of transactions or events one of the main purposes of which was to avoid or limit the application of Part IV.1 or VI.1, or
(I)another share of the corporation or a corporation related to the corporation that, if issued, would not be a taxable preferred share,(II)a right or warrant that, if exercised, would allow the person exercising it to acquire only a share of the corporation or a corporation related to the corporation that, if issued, would not be a taxable preferred share, or(III)both a share described in subclause (I) and a right or warrant described in subclause (II), and
(A)to ensure that any loss that the shareholder or a specified person in relation to the shareholder may sustain by reason of the ownership, holding or disposition of the share or any other property is limited in any respect, or(B)to ensure that the shareholder or a specified person in relation to the shareholder will derive earnings by reason of the ownership, holding or disposition of the share or any other property,
(c)the dividend entitlement of a share of the capital stock of a corporation shall be deemed not to be fixed, limited to a maximum or established to be not less than a minimum where all dividends on the share are determined solely by reference to the dividend entitlement of another share of the capital stock of the corporation or of another corporation that controls the corporation that would not be a taxable preferred share if(i)this definition were read without reference to paragraph (f),(ii)the other share were issued after June 18, 1987, and(iii)the other share were not a grandfathered share, a prescribed share or a share described in paragraph (e) of the definitionterm preferred sharein this subsection,(d)the liquidation entitlement of a share of the capital stock of a corporation shall be deemed not to be fixed, limited to a maximum or established to be not less than a minimum where all the liquidation entitlement is determinable solely by reference to the liquidation entitlement of another share of the capital stock of the corporation or of another corporation that controls the corporation that would not be a taxable preferred share if(i)this definition were read without reference to paragraph (f),(ii)the other share were issued after June 18, 1987, and(iii)the other share were not a grandfathered share, a prescribed share or a share described in paragraph (e) of the definitionterm preferred sharein this subsection,(e)where at any particular time after 8:00 p.m