Treatment of connected person and accommodating party

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

1. (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.