Section 99 of the Income Tax Act


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Section 99 of the Income Tax Act: Treatment of connected person and accommodating party

For the purposes of this Chapter, in determining whether a tax benefit exists,—

(ithe parties who are connected persons in relation to each other may be treated as one and the same person;

(ii) any accommodating party may be disregarded;

(iii) the accommodating party and any other party may be treated as one and the same person;

(iv) the arrangement may be considered or looked through by disregarding any corporate structure.


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