Cornerstone Research examined the economic substance of a partnership, addressing whether the partnership had features of an equity investment.
Cornerstone Research examined the economic substance of a partnership, addressing whether the partnership had features of an equity investment. Working with a finance professor, we constructed a model to simulate the future returns on an investment in the partnership. The model produced a probability distribution of returns that formed the basis of our expert’s opinion regarding the potential and economic substance of the partnership. The expert testified in tax court, and the judge found in favor of our clients.