Treatment of connected person and accommodating party.
Treatment of connected person and accommodating party.
182. In this Chapter, in determining whether a tax benefit exists,—
| (a) | the parties who are connected persons in relation to each other may be treated as one and the same person; |
| (b) | any accommodating party may be disregarded; |
| (c) | the accommodating party and any other party may be treated as one and the same person; |
| (d) | the arrangement may be considered or looked through by disregarding any corporate structure. |