- 53 - Clients establishing an offshore corporation or trust were charged fees for the service directly against their accounts. LTD’s gross receipts derived from charging an "opening expense" and an "annual expense". LTD’s direct costs were its payments to the third party lawyers and fiduciaries. The gross receipts and direct costs relating to LTD’s "Client Incorporation Fees" for each taxable year are as follows: TYE June 30 Gross Receipts Direct Costs 1986 $147,951 $18,286 1987 363,014 126,855 1988 290,518 161,037 1989 404,286 227,697 g. Legal Advice Income In an operating manual under the heading, "Legal Advise" (sic) LTD described its services regarding the creation of offshore corporations and trusts. The record reveals only that LTD derived gross receipts relating to "Legal Advice Income". LTD’s direct costs were the commissions that it paid to promoters for counseling clients regarding offshore corporations or trusts. The gross receipts and direct costs relating to LTD’s "Legal Advice Income" for each taxable year are as follows: TYE June 30 Gross Receipts Direct Costs 1988 $8,630 $3,453 1989 (328) 5,272 h. Letters of Credit LTD issued, either directly or through a bank, letters of credit to Mexican banks to secure loans for its clients. ThePage: Previous 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 Next
Last modified: May 25, 2011