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of <h1>Section 98: Impermissible Avoidance Arrangements May Lead to Denial of Tax Benefits and Recharacterization of Transactions</h1> If an arrangement is deemed an impermissible avoidance arrangement under Section 98, tax consequences may include denial of tax benefits or treaty benefits. Actions may involve disregarding, combining, or recharacterizing steps within the arrangement, treating it as non-existent, or merging parties for tax purposes. Connected persons may be treated as one, and accruals or expenditures can be reallocated. The residence of parties or the location of assets or transactions may be altered. Corporate structures might be disregarded, and equity can be treated as debt, capital as revenue, and vice versa, with recharacterization of expenditures or deductions.
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