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resolved included the ownership of the intangible assets and
licensing structure and clarification of the process of
transferring the intangible assets to the owner; the royalties
and management rates and contents of the supporting agreements;
and the method by which it was intended to repatriate the
“royalty” income to the beneficial owners of intangible assets,
who C&L understood were largely Spanish residents.
Louis deVries (deVries) was working with Medieval Times at
the C&L office in The Netherlands. deVries met with Santandreu
and Onate on November 19 and 20, 1986. At the meeting, they
discussed the “draft version of Ian Forsyth’s letter”.
Santandreu and Onate had specific questions about certain items
in the letter. Santandreu was of the opinion that the suggested
10- to 15-percent royalty rate discussed in the draft letter
should be calculated on gross income.
On December 9, 1986, Forsyth sent to deVries a memorandum
stating that C&L and Medieval Times had decided to use Manver to
hold the intangibles and to go ahead and try to get a tax ruling
for Manver from the Netherlands Antilles. Forsyth promised
deVries that he would forward a timetable of all of the actions
to be taken on behalf of Medieval Times in the next few days.
On December 11, 1986, the C&L office in the Netherlands
Antilles sent a letter to the Netherlands Antilles Inspector of
Taxes. The letter stated that Manver was going to be receiving
royalties from two NV companies that were operating amusement
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