Lack of commercial substance enables GAAR to disregard intermediaries and deny treaty or domestic tax benefits. An arrangement is deemed to lack commercial substance where the location of an asset, transaction, or a party's residence is chosen without substantial commercial purpose other than obtaining a tax benefit; where the main purpose is tax avoidance and a tainted element exists, GAAR permits disregarding intermediaries and denying treaty or domestic tax benefits even if the intermediary has nominal office or employees.