Plain meaning
A targeted anti-avoidance rule aimed at a specific type of transaction, structure, deduction, credit, or tax result.
Also called
specific anti-avoidance rules
Key points
- A SAAR is narrower than the General Anti-Avoidance Rule.
- It usually identifies a specific mischief, taxpayer group, transaction type, or calculation.
- SAARs can deny deductions, adjust amounts, deem relationships, recharacterize transactions, or impose reporting obligations.
- Tax planning often requires checking both the specific rule and broader anti-avoidance rules.
Why it comes up
SAARs matter because many tax disputes are resolved by specific provisions before broader GAAR analysis is needed.