- 37 - Percentage Partner Interest Gain Skokie .5 $633,333 Brunswick 9.5 12,033,334 Sodbury 90.0 114,000,000 Total 100.0 $126,666,667 The $126,666,667 gain that Saba reported on its March 31, 1990 tax return was not included on Saba's audited or unaudited financial statements for the year ended March 31, 1990. Saba invested the $160 million that it received on the sale of the Chase PPNs in time deposits and commercial paper. Saba acquired approximately $50 million of Brunswick commercial paper between September 20 and 26, 1990. Saba held Brunswick's commercial paper through April 3, 1991, when it contributed the commercial paper to SBC International Holdings, Inc. See discussion infra p. 44. C. McManaman's Tax Projections On April 20, 1990, McManaman prepared a schedule entitled "FOREIGN PARTNERSHIP TAX UPDATE" in which he projected that Brunswick would realize capital losses of $80 million attributable to "FOREIGN PARTNERSHIP I" (Saba) and capital losses of $57 million attributable to "FOREIGN PARTNERSHIP II" (the yet to be formed Otrabanda partnership). In addition, McManaman projected that Brunswick would realize capital gains of $91 million attributable to the sales of its Technical businesses and Nireco stock, that such capital gains would be offset byPage: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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