GAAR treatment of connected persons allows disregard of accommodating parties and look-through of corporate structures in tax benefit analysis.

GAAR treatment of connected persons and accommodating parties allows tax authorities, for determining whether a tax benefit exists, to treat connected persons as one person, disregard an accommodating party, combine an accommodating party with another party, and look through an arrangement by disregarding corporate structure. An accommodating party is one whose participation is mainly intended to secure a tax benefit for the assessee. Arrangement is defined broadly, and tax benefit includes reduction, avoidance, or deferral of tax, increase in refund, reduction in total income, or increase in loss. The same operative approach is carried forward from old section 99 to section 182.

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