Norwest Corporation and Subsidiaries - Page 52

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         local currency to the foreign company in exchange for its stock.             
         The commercial bank also recognizes a loss on the exchange of the            
         debt for the local currency to the extent of the excess of its               
         adjusted basis in the debt over the fair market value of the local           
         currency.  The ruling assumes that the fair market value of the              
         stock is equal to the fair market value of the foreign currency for          
         which it was exchanged.                                                      
              By applying the test enunciated in this ruling, respondent              
         argues that petitioner did not realize a loss on its exchange of             
         blocked deposits for cruzados because it received local currency             
         (cruzados) equal in value to its basis in the blocked deposits.              
         Moreover, respondent contends that petitioner recognizes no gain or          
         loss on the exchange of the cruzados for the PCC stock because the           
         ruling assumes that the value of the cruzados and the value of the           
         stock are identical.                                                         
              Respondent also contends  that G.M. Trading Corp. v.                    
         Commissioner, supra, supports its position.  G.M. Trading involved           
         a U.S. taxpayer that participated in a Mexican debt-equity swap.             
         In order to participate in the transaction, the taxpayer, a U.S.             
         company, formed a Mexican subsidiary, Procesos.  The U.S. company            
         then purchased a previously issued $1.2 million Mexican Government           
         debt from an unrelated bank for $634,000 (which reflected the                
         market discount rate of approximately 50 percent of the debt's               








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