- 4 -
SDI USA, Inc. (SDI USA), a corporation organized under the
laws of the State of California was, during the years at issue, a
wholly owned subsidiary of petitioner.
Petitioner also had subsidiary corporations in Germany,
France, and the United Kingdom.
A brochure used by the SDI Group for the years in issue
describes SDI Ltd. as the "Corporate Office" of the SDI Group,
and petitioner, SDI USA and other members of the SDI Group as
"Marketing" offices of the SDI Group.
SDI Ltd. provided management services to certain of its
direct and indirect subsidiaries for which such subsidiaries paid
it management fees.
Royalty Payments Made By Petitioner
During the years in issue, petitioner licensed from SDI
Bermuda, pursuant to a license agreement dated November 28, 1986
(Bermuda license agreement), the worldwide rights to certain
commercial systems software for use on IBM mainframe computers
(the software). The Bermuda license agreement granted petitioner
a nonexclusive license to use or to market the use of, on a
worldwide basis, all of the software and any and all industrial
and intellectual property rights SDI Ltd. had or would acquire
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011