- 90 - grants that were generally given only to manufacturing concerns that exported products from Ireland. Moreover, pursuant to an exemption that was generally available only with respect to goods manufactured in Ireland, B&L Ireland was relieved of its obliga- tion to pay Ireland's corporation tax with respect to practically all, if not all, of its income from its sunglass assembly opera- tions. Nor was B&L Ireland required to pay Ireland's VAT on the sunglass parts it imported into Ireland. This was because the regulations under the VAT provided an exemption for firms engaged in a manufacturing business that were importing goods for use in that business. Although we do not place determinative weight on the defini- tion of manufacturing used by other governments, that the Govern- ment of Ireland generally considered the assembly operations of B&L Ireland to constitute the manufacture of sunglasses is con- sistent with other evidence herein on which we rely supporting a finding that those operations, as well as the assembly operations of B&L Hong Kong, were generally considered to constitute the manufacture of sunglasses for purposes of section 954(d)(1) and section 1.954-3(a)(4)(iii), Income Tax Regs. On brief, respondent concedes that the respective assembly operations conducted by B&L Ireland and B&L Hong Kong were manu- facturing operations. Even her expert, Dr. Philpott, stated that "the processes and operations used [by B&L Ireland and by B&LPage: Previous 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 Next
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