- 5 -
Intercompany Accounts" (export promotion agreement) dated as of
February 1, 1980, that was also in effect during the periods
relevant to the instant case, certain departments within CV were
designated foreign marketing departments of CVI for purposes of
accounting for export promotion expenses within the meaning of
section 994(c) to be incurred by CVI and certain accounts were
designated as export promotion expense accounts. Pursuant to the
export promotion agreement, CVI obligated itself to reimburse CV
annually for export promotion expenses accounted for in the
designated accounts that were to be paid by CV in the first
instance. The export promotion agreement provided that CV would
bill the expenses to CVI at the close of CVI's fiscal year and
that the amount due was payable within 60 days after billing.
Pursuant to a written agreement entitled "Accounts
Receivable Purchase Agreement" (master receivables purchase
agreement) dated as of January 31, 1981, CVI was authorized to
purchase from time to time an undivided interest in CV's accounts
receivable arising from certain of the types of transactions that
give rise to qualified export receipts pursuant to section
993(a)(1) and on which CVI was entitled to receive a commission
(qualified export receivables). Pursuant to the master
receivables purchase agreement, the purchase price to be paid for
the undivided interest in the qualified export receivables was to
be determined at the time of purchase and was to reflect a
reasonable discount on the amount of the receivables purchased.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011