Treatment of connected person and accommodating party.99.
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.