- 209 -
personnel working in San Antonio." Petitioners assert that there
were only a handful of management-level employees working in
INC’s office in San Antonio, and that there was a relatively low
level of activity in that office, as evidenced by the low number
of telephone calls from that office to Mexico. Petitioners
contend that the income received by LTD from structuring and
executing currency transactions and from the TVA underwriting was
not generated from San Antonio by INC personnel.
Respondent contends that INC provided LTD with much more
than "back office services". Respondent argues that numerous
services were provided to LTD by INC: (1) INC provided all of
the services that LTD was obligated to provide to the third party
clients, (2) INC generated the spreads from U.S. and foreign
pooled investments by obtaining higher interest rates on
investments than those paid to clients, (3) account executives at
INC were the primary point of contact and information source for
financial transactions involving clients and promoters, (4)
account executives at INC maintained Account Cards on which they
recorded instructions that they received directly from clients
over the telephone and in person in the San Antonio office, (5)
INC employees implemented the clients' investment decisions,
monitored the clients' investments, acted as an interface between
clients and other financial institutions concerning currency
exchanges, money transfers, loans, and securities, and provided
current information to clients and promoters concerning various
investment products, (6) INC made all investment decisions on
Page: Previous 199 200 201 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 NextLast modified: May 25, 2011