Inverworld, Inc., et al. - Page 130

                                                - 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  Next

Last modified: May 25, 2011