https://www.taxtmi.com/caselaws?id=191809 A transaction entered into for fiscal advantage can still be a trading transaction if, viewed objectively, it is commercially real, profit-seeking, and capable of producing profit. On that basis, limited partnerships that acquired unfinished films, arranged completion, and exploited them for distribution were carrying on a trade and qualified for first-year allowances. The master negatives and associated film rights were held to belong to the partnerships, and expenditure funded through non-recourse borrowing still counted as expenditure incurred for the allowance provisions. The preordained structure was not disregarded under the Ramsay principle because the steps had independent commercial effect and were not mere paper devices. en-us Thu, 15 Jun 1989 00:00:00 +0530 Mon, 24 Apr 2017 18:21:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=191809 A transaction entered into for fiscal advantage can still be a trading transaction if, viewed objectively, it is commercially real, profit-seeking, and capable of producing profit. On that basis, limited partnerships that acquired unfinished films, arranged completion, and exploited them for distribution were carrying on a trade and qualified for first-year allowances. The master negatives and associated film rights were held to belong to the partnerships, and expenditure funded through non-recourse borrowing still counted as expenditure incurred for the allowance provisions. The preordained structure was not disregarded under the Ramsay principle because the steps had independent commercial effect and were not mere paper devices. Case-Laws Income Tax Thu, 15 Jun 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=191809