- 3 - banks and related companies in Montserrat. Under the laws of Montserrat, petitioner in 1985, 1986, and 1987, respectively, formed Guardian International Bank Ltd. (Guardian Bank), Guardian International Investment Services Ltd. (Guardian Services), and Stanford Financial Group Inc. (Stanford Financial), as controlled foreign corporations for the purposes of engaging in offshore banking and other activities. By 1990, petitioner owned 95 percent of the shares of stock in Stanford Financial. Stanford Financial, in turn, owned nearly 100 percent of the shares of stock in Guardian Bank and Guardian Services. Thus, by 1990, Guardian Bank and Guardian Services were brother/sister subsidiary corporations owned by Stanford Financial as the parent corporation. More specifically, on December 12, 1985, petitioner formed Guardian Bank as a Montserrat corporation for the purpose of engaging in certain offshore banking activities. Upon its formation, petitioner and petitioner’s father each owned 50 percent of the shares of stock in Guardian Bank. In its articles of association or charter, Guardian Bank's stated business purpose to engage in the business of banking was defined broadly and included administrative, management, and marketing functions relating to the business of banking, as follows: (1) To carry on the business of Banking in all its branches and to transact and do all matters and things incidentalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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