General anti-avoidance rule: broad definitions of tax benefit, connected persons, arrangements and accommodating parties constrain tax avoidance. Definitions establish an interpretive framework for the Chapter: an accommodating party participates to obtain a tax benefit; 'arrangement' and 'asset' are broadly defined to include steps, transactions, schemes and property; 'connected person' captures relatives, directors, partners, members and entities with substantial interests; 'fund' covers cash and equivalents; 'step' means measures or actions in a series; and tax benefit includes reductions, avoidance, deferral, increased refunds or effects on income or losses including via a tax treaty.
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: broad definitions of tax benefit, connected persons, arrangements and accommodating parties constrain tax avoidance.
Definitions establish an interpretive framework for the Chapter: an accommodating party participates to obtain a tax benefit; "arrangement" and "asset" are broadly defined to include steps, transactions, schemes and property; "connected person" captures relatives, directors, partners, members and entities with substantial interests; "fund" covers cash and equivalents; "step" means measures or actions in a series; and tax benefit includes reductions, avoidance, deferral, increased refunds or effects on income or losses including via a tax treaty.
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