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.
Under the agreement, Allied Solutions will become a wholly-owned subsidiary of Minnesota Life, but operate independently under the Allied Solutions brand and continue to represent the many providers whose products it distributes.
Allied Solutions was founded 25 years ago by a group including several former Minnesota Life associates, and the companies have marketed each other's products since 1999.
Under the agreement, Minnesota Life's sales and service personnel who work in regional offices will become employees of Allied Solutions, resulting in one field force of approximately 100 associates.