References in periodicals archive ?
The court further held that the partner's allocation of profits and losses was improper; the conduct of Allied and ABN demonstrated that the Bermuda agreement, which provided for a guaranteed return on investment for ABN, was the substance behind the formula provided by the partnership agreement.
As a result, the gains relating to the sale of the PPNs and the loss generated on the sale of the LIBOR notes were allocated entirely to the Allied affiliated group.
In light of Allied and ACM, taxpayers should more critically examine the substance of transactions involving partnerships, to ensure they will be respected.