- 9 - "intercompany account". On January 31, 1983, and prior to the application of the above-described payment by CVI to CV, CV held qualified export receivables as described in the master receivables purchase agreement and CVI was indebted to CV (1) pursuant to the export promotion agreement for expenses that previously had been paid by CV but had not yet been reimbursed by CVI and (2) for accrued State taxes that would be paid by CV in the first instance. At the time CVI wired the payment to CV, both CV and CVI intended that CVI would (1) purchase from CV the receivables of CV that were outstanding at the close of business on January 31, 1983, (2) reimburse CV for the aforementioned expenses, (3) pay CV an amount equal to the accrued State taxes, and (4) pay a dividend to CV from a portion of the transferred funds. All events necessary to determine the total amount of the receivables, expenses, and taxes had taken place by the close of business on that date; however, the information necessary to compute the total amount of the items was not available to CV and CVI's tax and accounting departments on that date. In prior years, CVI regularly had reimbursed CV for export promotion expenses pursuant to the export promotion agreement and for State tax payments. Additionally, CVI's and CV's tax and accounting departments did not have available to them on January 31, 1983, the information necessary to compute the amount of the dividend CVI intended to pay CV. At the time CVI made the foregoingPage: 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