- 118 - transferred $10 million to Gatetown. Gatetown transferred the money to MDT and MSI. MDT and MSI issued commercial paper to five entities that were controlled by the Spanish investors, notwithstanding that the five entities did not contribute any funds to MDT or MSI. MDT and MSI used the $10 million combined with promissory notes to pay Manver a total of $10 million cash and $12.5 million in promissory notes. To avoid withholding on the interest on the $12.5 million in notes to Manver, a round of commercial paper was issued. During March 1988, Manver transferred $9.03 million to Gatetown. The funds went through a myriad of controlled entities, within a day or two, and ended with MDT's transferring $7.672 million to Manver as payment on the royalties. Manver then transferred $2.672 million to Gatetown, which then transferred the money through a series of controlled entities, eventually to have $3.354 million transferred back to Gatetown, which transferred it to MSI, which in turn transferred it to Manver. Petitioners effectively used $7.672 million of funds supplied by Manver to reduce debts to Manver by $11 million. As subsequent rounds of commercial paper were issued, the interest payments that were made to the controlled entities were then distributed to the Spanish investors' Eurotor companies. The use of the commercial paper not only provided an opportunity to avoid withholding on the interest, it also provided a methodPage: Previous 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 Next
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