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July 1988, C&L Amsterdam sent to Forsyth drafts of promissory
notes that were dated 1987.
The correspondence was dominated by discussions on tax
rulings from the Netherlands Antilles. Randolph M. Th. de Cuba
of C&L sent letters dated September 30, 1988, to the Inspector of
Taxes in the Netherlands Antilles requesting tax rulings on
behalf of Manver, MTNV, and MANV. C&L wanted rulings for Manver
on the tax treatment of royalties, income, and whether or not
interest would be imputed on non-interest-bearing loans. The
ruling requests for MANV and MTNV concerned income, dividend
income from MABV, and whether or not interest would be imputed on
non-interest-bearing loans. The letters also provided that
Manver held the shares of MANV and MTNV, that MANV held all of
the shares of MABV, and that MTNV held all of the shares of MTBV.
C&L received the rulings it desired from the Inspector of Taxes
on October 6, 1988. The Inspector of Taxes agreed, among other
things, that interest would not be imputed on the specified non-
interest-bearing loans.
Some of the documents that purported to effectuate the
section 351 transfers were executed no earlier than late 1988,
although they were dated 1987. The documents for the Florida
side of the double section 351 transactions were dated August 1,
1987, one day after incorporation of MTBV. The documents
provided that, on that date, MTNV ceased doing business and
transferred its assets and business, subject to its liabilities,
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