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the borrower and the lender are not dealing at arm’s length, and
the borrower and the lender are not dealing at arm’s length, and
is, to the extent of the amount of the interest, if any, paid in respect of the security, deemed to have been payable on a security described in paragraph (a) of the definition fully exempt interest in subsection 212(3) if the security is described in paragraph (c) of the definition qualified security in subsection (1); and
is, to the extent of the amount of the interest, if any, paid in respect of the security, deemed to have been payable on a security described in paragraph (a) of the definition fully exempt interest in subsection 212(3) if the security is described in paragraph (c) of the definition qualified security in subsection (1); and