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of <h1>General Anti-Avoidance Rule treats connected persons as one, ignores accommodating parties and corporate structures to find tax substance</h1> For purposes of the General Anti-Avoidance Rule, when assessing whether a tax benefit exists the law permits treating persons who are connected as a single person, disregarding any accommodating party, treating an accommodating party and any other party as the same person, and looking through or disregarding corporate structures and arrangements to determine the true substance of transactions.
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