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To establish an offshore corporation or trust for a client,
a promoter in Mexico completed a form listing the client’s choice
of jurisdiction, and in the case of an offshore corporation, its
name, and the names of those individuals to be appointed
directors. The form was then sent by the promoter to INC, which
passed the information to outside lawyers or fiduciaries
qualified to perform the necessary paperwork in the chosen
jurisdiction.
The incorporation package completed by the lawyers or
fiduciaries was then returned to INC, which returned the package
to the client in Mexico. LTD's role, through the promoters, was
to provide the counseling on the structure and features of the
various incorporation options. Board of directors' meetings for
at least two companies incorporated by LTD clients were held at
INC’s offices in San Antonio. LTD's clients used as their
address the address of INC’s offices in San Antonio.
Clients establishing an offshore corporation or trust were
charged fees for the service, which were paid out of their
accounts. LTD charged the clients an "opening expense", which
consisted of LTD's fee and fees for third party lawyers and
fiduciaries, and an "annual expense". LTD’s direct costs were
its payments to the third party lawyers and fiduciaries, document
fees, commissions, and "incorporation expenses". The gross
receipts and direct costs relating to LTD’s "Client Incorporation
Fees" for each taxable year are as follows:
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Last modified: May 25, 2011