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Section 182

Treatment of connected person and accommodating party

In this Chapter, in determining whether a tax benefit exists,—

(a) the parties who are connected persons in relation to each other may be treated as one and the same person;

(b)
any accommodating party may be disregarded;
(c)
the accommodating party and any other party may be treated as one and the same person;
(d)
the arrangement may be considered or looked through by disregarding any corporate structure.