4.0 spec for ATOM and JSON formats doesn't define how values are represented when they are returned from operations (actions or functions).

For example, the following JSON format sections would appear to be only applicable only to a property within an entity or complex type instance.

7.1 Primitive Value
7.2 Complex Value
7.3 Collection of Primitive Values.
7.4 Collection of Complex Values
11 Individual Property

If a value of one of the above types is returned by an action or function, we need to define how it is represented.