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Background
Petitioner is a foreign corporation organized in 1974 under
the laws of the Kingdom of The Netherlands. Petitioner was
formerly known as SDI International B.V. and, prior to that, as
Software Design Dervis B.V.2 Petitioner is the successor in
business to Software Design Sebas B.V., a foreign corporation
organized in 1972 under the laws of the Kingdom of The
Netherlands.
At the time of filing the petition, petitioner maintained
its principal office in Rotterdam, The Netherlands.
During the years in issue, petitioner was a member of an
affiliated group of companies (the SDI Group) whose members
designed, manufactured, marketed, and serviced commercial systems
software for use on IBM mainframe computers worldwide.
SDI Ltd., a corporation organized under the laws of Bermuda,
is the parent company of the SDI Group. During the years in
issue, petitioner was a wholly owned subsidiary of SDI Antilles,
a Netherlands Antilles corporation, which was a wholly owned
subsidiary of SDI Ltd.
The SDI Group also included SDI Bermuda Ltd. (SDI Bermuda),
a corporation organized under the laws of Bermuda which, during
the years in issue was a wholly owned subsidiary of SDI Ltd.
2 Reference to petitioner and other corporations who are members
of the SDI Group herein includes predecessor corporations.
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Last modified: May 25, 2011