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    <title>1992 (3) TMI 354 - HOUSE OF LORDS</title>
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    <description>A pre-ordained composite film-financing arrangement had to be viewed as a whole for tax purposes, so self-cancelling steps and other commercially unreal elements were disregarded. The partnership&#039;s real expenditure was limited to the amount actually contributed and put at risk, not the larger figure routed through the scheme account. Applying that principle, first-year allowance was available only on $3.25m rather than $14m, because the taxing statute was applied to the transaction&#039;s true legal and fiscal effect, not its form.</description>
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    <pubDate>Thu, 12 Mar 1992 00:00:00 +0530</pubDate>
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      <title>1992 (3) TMI 354 - HOUSE OF LORDS</title>
      <link>https://www.taxtmi.com/caselaws?id=190420</link>
      <description>A pre-ordained composite film-financing arrangement had to be viewed as a whole for tax purposes, so self-cancelling steps and other commercially unreal elements were disregarded. The partnership&#039;s real expenditure was limited to the amount actually contributed and put at risk, not the larger figure routed through the scheme account. Applying that principle, first-year allowance was available only on $3.25m rather than $14m, because the taxing statute was applied to the transaction&#039;s true legal and fiscal effect, not its form.</description>
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      <pubDate>Thu, 12 Mar 1992 00:00:00 +0530</pubDate>
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