- 14 -14
exceeded 50 percent of the capital of all the partners, loss
would be allocated first to Barber and Dominguito to the extent
of the positive balance in their book capital accounts; then to
AlliedSignal and ASIC to the extent of the positive balance in
their book capital accounts; and the balance to each partner in
proportion to its respective partnership interest. If Barber's
and Dominguito's combined capital accounts did not exceed 50
percent, such loss would be allocated in proportion to each
partner's interest.
Capital Contributions: No interest would be paid on any
capital contributions to the partnership, and capital accounts
would be maintained in accordance with section 1.704-1(b), Income
Tax Regs.
D. Miscellaneous ASA Matters
ASA engaged Merrill Lynch as its financial adviser (e.g.,
Merrill Lynch calculated the value of ASA's investments) and N.V.
Fides, a Netherlands Antilles affiliate of ABN, as its investment
adviser. The Curacao office of N.V. Fides was the principal
office of ASA, and all of ASA's business was to be conducted at
such office. Pursuant to authorization from N.V. Fides, ABN
opened the "ASA Investerings Partnership Custody Account" at ABN
New York's office and placed ASA's commercial paper in ABN New
York's vault at Bankers Trust. ASA adopted a fiscal year ending
on May 31 (i.e., consistent with Dominguito's, the majority
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011