In determining the source of a nonresident partner's income, effect may not be given to a provision in the partnership agreement that
(1) characterizes payments to the partner as being for services or for the use of capital;
(2) allocates to the partner, as income or gain from sources outside the state, a greater proportion of the partner's distributive share of partnership income or gain than the ratio of partnership income or gain from sources outside the state to partnership income or gain from all sources; or
(3) allocates to the partner a greater proportion of a partnership item of loss or deduction connected to Alaska sources than the partner's proportionate share, for federal income tax purposes of partnership loss or education generally.
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