- 6 - The agreement also provided that CV would produce, upon demand by CVI, a list of the qualified export receivables in which CVI had an interest, including the identity of the account debtor, the amount of each receivable, and the date on which it arose. CV was required to bill and collect all payments on the qualified export receivables in which CVI had an interest on CVI's behalf and, unless requested to remit the proceeds to CVI, to substitute an undivided interest in additional receivables for those discharged. Using the commissions paid it by CV, CVI, pursuant to the master receivables purchase agreement, periodically purchased at a discount interests in CV's qualified export receivables that were qualified export assets within the meaning of section 993(b). During its 1981 taxable year, CV entered into the following sales of qualified export receivables to CVI at a discount under the master receivables purchase agreement: Date of Sale Receivables Face Amount Oct. 1, 1981 $23,345,288 Oct. 15, 1981 1,874,000 Dec. 1, 1981 4,028,369 Under the terms of the sales, CV was obligated to pay to CVI all proceeds collected with respect to CVI’s interest in the qualified export receivables on September 30, 1982. During 1982, CV made an election to use the installment method to report its income with respect to domestic and foreign sales. Because CV believed that further purchases of qualifiedPage: 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