Algemene Bank Nederland N.V.

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14 documents for Algemene Bank Nederland N.V.

- Whither corporate tax shelters?
Two court decisions in late 1998 ruled against the use of corporate tax shelters. The Tax Court ruled in ASA Investerings Partnership v. Commissioner that tax shelters provided by an investment bank were not valid because the bank was not actually a partner in an arrangement meant to represent the bank as a partner. The US 3d Circuit Court of Appeals affirmed the Tax Court's decision in ACM v. Commissioner, ruling that a series of collateral swaps arranged by Merrill Lynch to reduce taxes on a $105 mil sale by Colgate-Palmolive Co. did not have economic substance.

... was not told, Merrill Lynch had selected Algemene Bank Netherlands N.V. (ABN) to serve as the foreig... the large Dutch bank, Algemene Bank Nederland, N.V. (ABN). ABN had a prior relationship with Mer...
- Tax Executive
- Vol. 51 Nbr. 2, March 1999
- MoFo Tax Talk, Volume 4, Issue 2 - July 2011
..., (ii) that are associated with a private banking relationship, and (iii) that have a balance/value ... interest rate swap transactions with Algemene Bank Nederland, N.V. ("ABN"), a Dutch bank. Under ...
- Mondaq Business Briefing
- United States Law Articles in English
- Banca Del Sempione, Plaintiff-Appellee, v. Provident Bank of Maryland, Defendant-Appellant, and Suriel Finance N.V., Defendant, Jeanne Farnan, Party in Interest. United States Council on International Banking, Incorporated, Amicus Curiae., 160 F.3d 992 (4th Cir. 1998)
...See Sempione II, 75 F.3d at 964; Algemene Bank Nederland, N.V. v. Soysen Tarim Urunleri Dis ...
- Federal Circuits

- MoFo Tax Talk, Volume 2, Issue 3.
... interest rate swap transactions with Algemene Bank Nederland, N.V. ("ABN"), a Dutch bank. Under ...
- Mondaq Business Briefing
- Nbr. 2009, January 2009
- Gain an Insight into the Latest Mergers & Acquisitions within the World's Banking Industry.
... Amro Bank Germany (Germany) - ABN Amro Bank NV (Japan) - ABN Amro Bank NV (Sweden) - ABN Amro Ban..., NA (USA) - Alfa-Bank (Russia) - Algemene Bank Nederland NV (Malaysia) - Allahabad Bank (Ind...
- Business Wire
- July 18, 2006
- ACM Partnership, Southampton-Hamilton Company, Tax Matters Partner, (1997)
...In 1989, M, an investment banking firm, approached C with an elaborate scheme to she... issue, ABN New York was a subsidiary of Algemene Bank Nederland, N.V., one of the Netherlands' larg...
- United States Tax Court
- 3Com Corporation, Plaintiff-Appellee, v. Banco Do Brasil, S.A., Defendant-Appellant., 171 F.3d 739 (2nd Cir. 1999)
... and a seller, (2) an agreement between a bank and its customer (the buyer), pursuant to which th...44, 46 (S.D.N.Y.1994); Algemene Bank Nederland, N.V. v. Soysen Tarim Urunleri Dis ...
- Federal Circuits
- ACM Partnership v. Commissioner IRS, (3rd Cir. 1998)
... 25, 1989, as an entity controlled by Algemene Bank Nederland N.V. ("ABN"), a major Dutch bank. A...
- Federal Circuits
- MoFo Tax Talk, Volume 2, Issue 3
... interest rate swap transactions with Algemene Bank Nederland, N.V. ("ABN"), a Dutch bank. Under ...
- Mondaq Business Briefing
- United States Law Articles in English
- Aetna Life and Casualty Company, Plaintiff-Appellant, v. Huntington National Bank, Defendant-Appellee., 934 F.2d 695 (6th Cir. 1991)
...) provided fidelity bond coverage to Algemene Bank Nederland, N.V. (ABN) to cover losses to ABN ...
- Federal Circuits