- 6 - being deposited with or withdrawn from U.S. institutions, including Frost Bank in San Antonio, where the clearing account was maintained. Additionally, INC maintained records of LTD’s and its clients’ positions with respect to such currency transactions. LTD ceased to conduct the currency transactions in its own name as of its taxable year ended June 30, 1989. LTD's currency transaction income derived from, inter alia, the fees, which were reflected in the exchange rates, that LTD charged its clients. The gross receipts and direct costs relating to LTD’s income from "Currency Transactions" for each taxable year are as follows: TYE June 30 Gross Receipts Direct Costs 1985 1$531,003 - 0 - 1986 745,001 130,485 1987 2434,867 16,125 1988 3232,426 16,863 1This amount is net of expenses. Neither the revenue agent's workpapers nor Deloitte's workpapers reveal the gross receipts. 2The amount of gross receipts includes a check of $11,361 from the Guadalajara office representing its contribution to profits. 3The amount of gross receipts includes a check of $16,426 from the Guadalajara office representing its contribution to profits. c. Client Incorporation and Trust Creation Fees LTD offered its clients the option of establishing offshore corporations and trusts to hold their investments. Each client signed a discretionary authorization granting LTD the power to invest the funds held by the client’s corporation or trust.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