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charged the client a fee equal to the difference between the
exchange rate obtained from the Mexican exchange house and the
rate quoted and agreed to by the client.
ii. LTD sold dollars from its own account to a client in
exchange for pesos. LTD transferred money, usually by wire, from
the clearing account to the client's designated financial
institution. The transaction appeared on LTD's books as a debit
in the clearing account.
iii. LTD arranged purchases of dollars from a client in
exchange for pesos. LTD verified that the client had sufficient
funds on deposit in its account with LTD. The client then
withdrew dollars from its LTD account to exchange with pesos
obtained by LTD. The transaction appeared as a debit on the
client's monthly statement.
iv. LTD purchased dollars from a client in exchange for
pesos and deposited the dollars into LTD's own account. The
transaction appeared on LTD's books as a credit to the clearing
account.
Only transaction type (i) above involved the performance of
personal services in Mexico by a promoter. Specifically, in
transaction type (i), the promoter handled the exchange by
converting pesos to dollars at a Mexican exchange house. In
transactions types (ii), (iii), and (iv), the currency
transactions were handled by INC in San Antonio with pesos being
deposited with or received from Mexican institutions and dollars
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Last modified: May 25, 2011