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Anti-avoidance, H A R E, C L O S A C S - Coggle Diagram

- - - - Ctrl trans (>50% / >=20% + conditions)
        
        persons whom has ctrl
        
        both of whom ctrl by 3rd person
        
        Conditions
        
        depend on proprietary rights by other person
        
        bs actv specified by other person
        
        appoint >=1 directors
      - EBITDA = A + B + C
        
        A = adj bs inc
        
        B = total amt of qualifying ded allowed (ie. DD)
        
        C = total amt of int exp of financial assistance from bs source
      - Int exp >20%
        
        excess c/f, if
        
        s/h on 1st & last day substantially the same (>50% pd up OSC held by same persons)