CRA’s view of the acting-in-concert doctrine may be overly broad

CRA’s statement in Folio S1-F5-C1 that "Even when there are two distinct parties (or minds) to a transaction, but these parties act in a highly interdependent manner (in respect of a transaction of mutual interest), then it can be assumed that the parties are acting in concert and therefore are not dealing with each other at arm's length" may very well be an overly expansive reading of the acting-in-concert jurisprudence.  The Joint Committee expressed scepticism as well.

Neal Armstrong.  Summary of Sandra Mah and Mark Meredith, "Factual Non-Arm's Length Relationships," draft version of paper for CTF 2014 Conference Report, under s. 251(1)(c).