Apportionment or allocation where two or more organizations, trades or businesses are owned or controlled by the same interests
Source:
Section 314.295 — Apportionment or allocation where two or more organizations, trades or businesses are owned or controlled by the same interests, https://www.oregonlegislature.gov/bills_laws/ors/ors314.html
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Notes of Decisions
Although limited partnership was not engaged in trade or business, transactions in which real property was transferred in order to generate losses and to funnel income into tax exempt profit sharing trust were not illegal or shams and defendants failed to show that they were not equivalent to arm’s length transactions. Allison v. Dept. of Rev., 11 OTR 431 (1990)
Transaction lacking substantial legal and economic significance aside from tax considerations as to both buyer and seller is sham. Baisch v. Dept. of Rev., 316 Or 203, 850 P2d 1109 (1993)