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U.S. tax returns for calendar years 1984, 1985, 1986, 1987, 1988,
and 1989, or its taxable years ended June 30, 1987, 1988, and
1989. During each of its taxable years ended June 30, 1984
through 1989, LTD did not file income tax returns with any
governmental entity, either foreign or domestic. LTD did not
file any statements, forms, or other documents in lieu of income
tax returns in Mexico or the Cayman Islands.
INC maintained its books and records using a June 30
taxable year. INC filed U.S. Corporation Income Tax Returns
(Forms 1120) for taxable years ended June 30, 1985 and 1986. INC
did not file U.S. Annual Withholding Tax Returns for U.S. Source
Income of Foreign Persons (Forms 1042) for calendar years 1987,
1988, and 1989. For its taxable years ended June 30, 1987, 1988,
and 1989, INC was joined in the consolidated income tax returns
filed by Holdings.
Holdings maintained its books and records using a June 30
taxable year. Holdings filed U.S. Corporation Income Tax Returns
(Forms 1120) for taxable years ended June 30, 1987, 1988, and
1989.
C. Creation of LTD
LTD was created by principals of InverMexico, S.A. de C.V.,
Casa de Bolsa, which was a securities brokerage firm that was
registered in Mexico and headquartered in Mexico City, Mexico.
On November 27, 1981, LTD was incorporated as an exempted
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