Amalgamation rules: merger transfers all assets and liabilities and requires a shareholder supermajority for tax recognition. Amalgamation denotes a corporate merger in which the amalgamated company succeeds to all property and all liabilities of the amalgamating company or companies immediately before the amalgamation, and where shareholders holding a qualifying supermajority in value (excluding shares already held by the amalgamated company or its subsidiary) become shareholders of the amalgamated company by virtue of the amalgamation; acquisitions by purchase or distributions after winding up are excluded from this treatment.