Income Tax Act — I-3.3 18.2
 that one of the main purposes of the particular taxpayer being, becoming or ceasing to be an eligible group entity, in respect of the other taxpayer, a financial institution group entity or a financial holding corporation is to enable any taxpayer to obtain a tax benefit (within the meaning of subsection 245(1)), the particular taxpayer is deemed not to be, to have become, or to remain, as the case may be, an eligible group entity, in respect of the other taxpayer, a financial institution group entity or a financial holding corporation, as the case may be, at that time. Benefits conferred (10) For the purposes of this Part, if a transferor and a transferee file an election (including an amended election) under subsection (4), no benefit is considered to have been conferred on the transferee as a consequence of the election. Consideration for election (11) For the purposes of this Part, if property is acquired at any time by a transferor as consideration for filing an election or amended election with a transferee under subsection (4) (a) where the property was owned by the transferee immediately before that time, (i) the transferee is deemed to have disposed of the property at that time for proceeds equal to the fair market value of the property at that time, and (ii) no amount may be deducted in computing the transferee’s income as a consequence of the transfer of the property, except any amount arising as a consequence of subparagraph (i); (b) the cost at which the property was acquired by the transferor at that time is deemed to be equal to the fair market value of the property at that time; and (c) the transferor is not required to add an amount in computing income solely because of the acquisition at that time of the property. Partnerships (12) For the purposes of this section, (a) a person or partnership that is (or is deemed by this paragraph to be) a member of a particular partnership that is a member of another partnership is deemed to be a member of the other partnership; and (b) a person’s share of the income or loss of a partnership includes the person’s direct or indirect, through one or more other partnerships, share of that income or loss. Anti-avoidance — interest and financing revenues and expenses (13) A particular amount that would, in the absence of this subsection, be included under the description of A in the definition interest and financing revenues , or the description of B in the definition interest and financing expenses , in computing the income or loss of a taxpayer for a taxation year, must not be so included, if (a) an amount in respect of the particular amount is deductible in computing the foreign accrual property income of a corporation that is a foreign affiliate, but not a controlled foreign affiliate, of the taxpayer or of a person or partnership that does not deal at arm’s length with the taxpayer; (b) the particular amount is received or receivable, directly or indirectly and in whole or in part, by the taxpayer, or a partnership of which it is a member, from (i) a person that does not deal at arm’s length with the taxpayer and that is (A) an excluded entity, (B) a natural person, or (C) if the taxpayer is not a financial institution group entity or a financial holding corporation, a financial institution group entity or a financial holding corporation, or (ii) a partnership of which a person described in subparagraph (i) is a member; or (c) one of the main purposes of a transaction or series of transactions is to include the particular amount under the description of A in the definition interest and financing revenues , or the description of B in the definition interest and financing expenses , in computing the income or loss of the taxpayer for a taxation year and (i) the transaction or series results in an amount that (A) is not included in the description of B in the definition interest and financing revenues , or the description of A in the definition interest and financing expenses