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Oteyza and Jaime Antonio Mayol Castaner (Mayol), Segui’s brother-
in-law.
In a letter to the United Kingdom taxing authority in 1987,
Harris represented that Gatetown commenced business March 1,
1986; that Gatetown’s registered office was in Palma de Mallorca,
Spain; and that the nature of the company’s activities was as
owner of royalty and copyright agreements. Gatetown’s original
incorporators resigned on June 12, 1986, and Mayol and de Oteyza
were named as the officers. The Gatetown stock, which consisted
of two shares, was held equally by Mayol and de Oteyza as
nominees.
On May 1, 1986, A. Gelabert sent to Francois A. Nouel
(Nouel) of CANV a letter requesting that, among other things,
Nouel submit the names of Manver, Lince, and Attractours for
approval by the Chamber of Commerce of the Netherlands Antilles.
Attractours, Lince, N.V. (Lince), and Manver, N.V. (Manver), were
incorporated in the Netherlands Antilles on or about May 16,
1986. Lince was owned by Holiday, Roundabout, Dapy, and
Promidux. Manver was owned by Spectrust and Wayout. Attractours
was owned by Promidux and Dapy. The Manver incorporation fees
were paid by Wayout. Lince was capitalized with $6,000 on
May 19, 1986, from an account maintained in the name of Holiday.
Ian Forsyth (Forsyth) was the international tax partner at
the C&L Los Angeles, California, office from 1986 to 1989. As
appears from his handwritten notes and related correspondence,
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