If this Subdivision applies to a * realisation event that happens to an * affected interest in the * gaining entity, a gain that would, apart from this Division, be * realised for income tax purposes by the event is reduced by an amount that is reasonable having regard to:
(a) a reasonable estimate of the amount (if any) by which the * indirect value shift has increased the interest's * market value; and
(b) a reasonable estimate of the extent (if any) to which the interest's market value at the time of the realisation event still reflects the effect of the indirect value shift on the market value of * equity or loan interests in the gaining entity.