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3. Double Wealth Co., Inc.
Double Wealth Co., Inc. (Double Wealth) was incorporated in
Liberia on January 7, 1985, and, at all relevant periods after
January 7, 1985, one share of the stock of Double Wealth was held
in the name of Mme. Koo. During the years at issue, petitioner,
Ms. Gaw, and Mme. Koo were the directors of Double Wealth. At
least during 1985, petitioner was Double Wealth's chairman and
president and Ms. Gaw was its secretary and treasurer.
4. Forward Investments, Ltd.
Forward Investments, Ltd. (Forward) was incorporated in
Liberia on December 3, 1980. During that month, one share of
stock of Forward was issued in the name of Mme. Koo. During the
years at issue, petitioner, Ms. Gaw, and Mme. Koo were the
directors of Forward. At least during 1984 and 1985, Ms. Gaw was
the secretary of Forward.
As of June 25, 1985, petitioner had given his personal
guarantee for $3,800,000 to Standard Chartered Bank, Hong Kong
(Standard Chartered Bank HK), an affiliate of Union Bank, as
security for credit made available to Forward by Standard Char-
tered Bank HK.
D. Bangkok Bank Ltd.
During the years at issue, Bangkok Bank Ltd., a Thai banking
corporation, was engaged in the banking business in California
and Hong Kong through unincorporated branches located in Los
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