(2)For the purposes of sub-section (1), round trip financing includes any arrangement in which, through a series of transactions -(a)funds are transferred among the parties to the arrangement; and(b)such transactions do not have any substantial commercial purpose other than obtaining the tax benefit (but for the provisions of this Chapter),without having any regard to -(A)whether or not the funds involved in the round trip financing can be traced to any funds transferred to, or received by, any party in connection with the arrangement;(B)die time, or sequence, in which the funds involved in the round trip financing are transferred or received; or(C)the means by, or manner in, or mode through, which funds involved in the round trip financing are transferred or received.
