Then I think we're just getting hung up on the labguage concerning what is 'necessary' or 'un-necessary'. I'd actually be interested to hear about the level of

Then I think we're just getting hung up on the labguage concerning what is 'necessary' or 'un-necessary'. I'd actually be interested to hear about the level of abstraction of your systemic data, just to be more clear on where you are coming from. Again, my comment up-thread was not in any way impugning a particular trade or trade structure. If you are a practitioner, you're well aware of the level of detail required to opine on something so specific. As a general rule though the more complex any transaction is (whiteboard+lawyers) the more legal grey there are. That is a statement I'm comfortable with in general.