You're probably right. We often have the legal idea of "arm's length" meaning a transaction that is coincidental or purposeful will be treated differently. I f

You're probably right. We often have the legal idea of "arm's length" meaning a transaction that is coincidental or purposeful will be treated differently. I find this interesting in your link: "if a transaction has no substantial business purpose other than the avoidance or reduction of Federal tax, the tax law will not regard the transaction" I don't see how that doesn't apply to all the shuffling we see from big corps these days, licensing things they own to companies they own just to shift profits. Though that's another tangent.