- 35 -
or a November 30 fiscal year for MANV and Calinvest to delay the
effect of the 1986 Tax Reform Act with respect to the 30-percent
withholding tax. Forsyth listed the information that was
required as soon as possible, which included balance sheets;
profit and loss statements; profit forecasts; recent tax returns;
a listing of all agreements, licenses, etc., that would need to
be transferred to the new U.S. subsidiaries; and details of the
shareholdings of the Netherlands Antilles companies. Forsyth
needed the information to prepare a tax benefit forecast and a
final version of the detailed letter he had reviewed with
Santandreu.
During October 1986, it had not yet been determined who
would own the intangibles. While C&L, with the Spanish
investors’ knowledge, was drafting documents that named Manver as
the “licensor” of the intangibles, the Spanish investors were
also taking steps to have Gatetown own the intangibles. In an
October 22, 1986, letter from Harris, the United Kingdom
accountants, to “The Directors, Gatetown Limited, Euritor”,
Harris stated their understanding of the current situation and
the proposed steps to be taken with regard to the setting up of
the trading operation of Gatetown Limited in the United Kingdom.
The letter included the following information:
An “NV” Corporation exists with 20% of that Corporation
being owned by Spanish individuals and 80% by 7 “arms-
length” “NV” Companies. * * * Gatetown Limited has
agreed to buy the United States and Canadian copyright
and Royalties from a Spanish Corporation in respect of
Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 NextLast modified: May 25, 2011