definiens: within the meaning of the ITA ; 26 ( p ) Nant Health Canada has not acquired property or services from, or disposed of property or provided services to, a person with whom it does no t deal at arm ’s length ( within the meaning of the I TA ) for an amount that is other than the fair market value of such property or services, nor has Nant Health Cana da been deemed to have done so for purposes of the ITA . For all transactions between Nant Health Canada, on th e one hand, and any non - resident Person with whom Nant He alth Canada was not dealing at arm ’s length, for th e purposes of the ITA, on the other hand, Nant Health Canada has made or obtained records or documents t hat satisfy the requirements of paragraphs 247(4)(a ) to ( c ) of the ITA ; and ( q ) there are no circumstances existing which could result in the application of section 17, section 78, section 79, or sections 80 to 80.04 of the ITA, or any equivalent provision under applicable provi ncial law, to Nant Health Canada . Nant Health Canada has not clai med nor will it, prior to the Closing, claim any re serve under any provision of the ITA or any equivalent pr ovincial provision, if any amount could be included in the income of Nant Health Canada for any period ending after the Closing Date