(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)the 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.