26 CFR · Internal Revenue
§ 1.5000C-5 — Anti-abuse rule.
26 CFR § 1.5000C-5
This text of 26 C.F.R. § 1.5000C-5 (Anti-abuse rule.) is published on Counsel Stack Legal Research, covering United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Bluebook
26 C.F.R. § 1.5000C-5 (2026).
Text
§ 1.5000C-5 Anti-abuse rule.
If a foreign person engages in a transaction (or series of transactions) with a principal purpose of avoiding the tax imposed under section 5000C, the transaction (or series of transactions) may be disregarded or the arrangement may be recharacterized (including disregarding an intermediate entity), in accordance with its substance. If this section applies, the foreign person remains liable for any tax (including any tax obligation unsatisfied as a result of underwithholding) and the Internal Revenue Service retains all other rights and remedies under any applicable law available to collect any tax imposed on the foreign contracting party by section 5000C.
[T.D. 9782, 81 FR 55138, Aug. 18, 2016]
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Related
§ 1.5000
26 C.F.R. § 1.5000
Nearby Sections
11
§ 1.5000C-5
Anti-abuse rule.§ 1.5000C-6
Examples.§ 1.5000C-7
Effective/applicability date.§ 1.6001-1
Records.§ 1.6001-2
Returns.Cite This Page — Counsel Stack
Bluebook (online)
26 C.F.R. § 1.5000C-5, Counsel Stack Legal Research, https://law.counselstack.com/cfr/26/1/1.5000C-5.