Page 57 - Large Business IRS Training Guides

Additional Considerations

owner
• Existing law applies to determine the beneficial
and the related tax consequences,
of income/asset

principles, case law conduit
including principal-agent
principles,
and assignment of income, as well as the

appropriate treatment
of a payment

• Anti-abuse rules

• Transactions involving unrelated persons, conduits, and

intermediaries

• Transactions to increase the amount of deductions taken

of the BE%
into account in the denominator

• Transactions to avoid the application of rules applicable

dealers
to banks and registered securities

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