Anthony Teong-Chan Gaw as Transferee of Radcliffe Investment LTD. - Page 43

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            Angeles (Bangkok Bank LA branch or Los Angeles branch) and Hong                                
            Kong (Bangkok Bank HK branch or Hong Kong branch), respectively.                               
            During those years, the interest income earned by Bangkok Bank LA                              
            branch in its lending activity was effectively connected with the                              
            conduct of its banking business in California.                                                 
                  Radcliffe began dealing with Bangkok Bank LA branch in May                               
            1984.  No later than the years at issue, certain of the foreign                                
            corporations that pledged cash collateral in one or more of                                    
            thetransactions at issue in which the Los Angeles branch and/or                                
            the Hong Kong branch of Bangkok Bank Ltd. was involved (viz.,                                  
            Intercontinental Enterprises Corp. of Liberia (Intercontinental),                              
            Traveluck, and Double Wealth) maintained at least one account                                  
            with Bangkok Bank HK branch.  Prior to and during the years at                                 
            issue, Pioneer and at least certain of its subsidiaries, includ-                               
            ing its wholly owned subsidiaries Multi-Credit and Mandalay, had                               
            banking relationships with Bangkok Bank Ltd.  Prior to and during                              
            the years at issue, Pioneer and at least certain of its sub-                                   
            sidiaries, including Mandalay,5 owned stock in Bangkok Bank Ltd.6                              
                  The annual reports of Pioneer for its fiscal years ended                                 
            March 31, 1983, and March 31, 1984, indicated that for each such                               
            year (1) Pioneer held 1.6 percent and its subsidiaries held 1.6                                

            5  Mandalay held .91 percent of the equity of Bangkok Bank Ltd.                                
            as of Mar. 31, 1984, and .83 percent of that equity as of Mar.                                 
            31, 1985, and Mar. 31, 1986.                                                                   
            6  Petitioner notes on brief that Pioneer's subsidiaries included                              
            a subsidiary in which Pioneer owned 60 percent of the equity.                                  
            The record does not disclose whether or not that subsidiary owned                              
            any stock in Bangkok Bank Ltd.                                                                 


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