- 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 onPage: 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