Section 99 — Treatment of connected person and accommodating party.

Treatment of connected person and accommodating party.—For the purposes of this Chapter, in determining whether a tax benefit exists,— (i) the parties who are connected persons in relation to each other may be treated as one and the same person; (ii) any accommodating party may be disregarded; (iii) the accommodating party and any other party may be treated as one and the same person; (iv) the arrangement may be considered or looked through by disregarding any corporate structure.

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