| (a) | - | the substance or effect of the arrangement as a whole, is inconsistent with, or differs significantly from, the form of its individual steps or a part; or |
| (b) | - | it involves or includes- |
| (i) | - | round trip financing; |
| (ii) | - | an accommodating party; |
| (iii) | - | elements that have effect of offsetting or can .... To read the full section download the app from Google Play store
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