General anti avoidance rule treats connected persons as a single taxpayer and disregards accommodating parties to prevent tax benefit. The General Anti Avoidance Rule provides that connected persons may be treated as one and the same person when determining a tax benefit; accommodating parties may be disregarded; an accommodating party and any other party may be treated as one and the same person; and arrangements may be looked through by disregarding corporate structure to assess the substantive tax position.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
General anti avoidance rule treats connected persons as a single taxpayer and disregards accommodating parties to prevent tax benefit.
The General Anti Avoidance Rule provides that connected persons may be treated as one and the same person when determining a tax benefit; accommodating parties may be disregarded; an accommodating party and any other party may be treated as one and the same person; and arrangements may be looked through by disregarding corporate structure to assess the substantive tax position.
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