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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&L
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