TaxTMI Login
Just a moment...
Press 'Enter' to add multiple search terms. Rules for Better Search
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Acts & Rules
of of All Acts & Rules
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>Arrangements Lack Commercial Substance When Form Differs from Substance, Involves Round Trip Financing or Tax-Driven Purposes.</h1> An arrangement is considered to lack commercial substance if its overall substance or effect significantly differs from its form, involves round trip financing, an accommodating party, or transactions that disguise the value or control of funds. It may also lack substance if the asset location or transaction has no substantial commercial purpose other than tax benefits, or if it doesn't significantly affect business risks or cash flows aside from tax benefits. Round trip financing involves funds transferred among parties without substantial commercial purpose. Factors like the arrangement's duration, tax payments, or exit routes are relevant but insufficient to determine commercial substance.
TaxTMI 
TaxTMI 
