REGULATIONS DEALING WITH CONDUIT ARRANGEMENTS.

SEC. 13238. REGULATIONS DEALING WITH CONDUIT ARRANGEMENTS. Section 7701 is amended by redesignating subsection (1) as subsection (m) and by inserting after subsection (k) the following new subsection: “(1) Regulations Relating to Conduit Arrangements.— The Secretary may prescribe regulations recharacterizing any multiple-party financing transaction as a transaction directly among any 2 or more of such parties where the Secretary determines that 107 STAT. 509such recharacterization is appropriate to prevent avoidance of any tax imposed by this title.”