Presumption of tax purpose shifts burden to taxpayer to prove tax benefit was not the main purpose of an arrangement.

An arrangement is presumed to have been entered into or carried out for the main purpose of obtaining a tax benefit unless the person proves otherwise; if any step or part of an arrangement has as its main purpose obtaining a tax benefit, the arrangement is likewise presumed to have been made or carried out for that main purpose, even if the overall arrangement's main purpose is not to obtain a tax benefit.

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