(1) An * indirect value shift does not have consequences under this Division if the amount of it does not exceed $50,000.
(2) However, subsection (1) does not apply to an * indirect value shift (and is taken never to have applied to it) if:
(a) before, at the same time as, or after it, another indirect value shift happens for which the same entity is the losing entity as for the first indirect value shift; and
(b) having regard to all relevant circumstances, it is reasonable to conclude that the sole or main reason why one of the indirect value shifts happened under a different * scheme from the other was so that its amount would not exceed $50,000.