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Forsyth was aware of the Medieval Times company early in 1986,
prior to purchase of the California castle.
In May 1986, Forsyth met with representatives of the
Medieval Times companies at C&L in Los Angeles. During the
numerous meetings that occurred, Forsyth met primarily with
Santandreu, Jeronimo Onate (Onate), and A. Gelabert. Santandreu
and Onate represented the Medieval Times companies and Gatetown
or Manver or both. Kenneth H. Kim (Kim) was employed at C&L as a
tax manager and assisted Forsyth in the representation and
meetings.
During a May 20, 1986, meeting, the then-existing structure
of the Medieval Times companies was reviewed with Forsyth.
Forsyth began to design methods intended to improve the corporate
structure of the Medieval Times U.S. entities. Forsyth thought
the “branch profits tax” in the Tax Reform Act of 1986, Pub. L.
99-514, 100 Stat. 2085, would make the existing structure of
Medieval Times undesirable.
Forsyth took notes at these meetings. Notes dated May 20,
1986, contain the following references: “Royalties. Recommend
trademark attorney. None registered. Which company should own
trademark - where? Copyright - Which Co.? 3 Spanish nationals
‘own’. (Florida Co. Not now paying royalties)”. The notes also
state: “Trademark - offshore. Objective: 10% [royalty] of pre-
tax [profit]. Problem: Ownership of intangibles.”
Additionally, the notes reflect that the Spanish operation
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