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Amount in
Item U.S. Dollars
Royalty income $ 3,865,283
Interest income 3,990,947
Exchange gains 12,371,700
Total gross income $20,227,930
By stipulation of the parties, $7,856,230 constituted gross
subpart F income, and the exchange gain of $12,371,700 did not
constitute gross subpart F income for purposes of section 952(a).
The parties disagree as to the allocation and apportionment
of the following expenses incurred by AG:
Amount in
Item U.S. Dollars
Interest $1,498,562
Swap losses 3,259,120
Capital tax 438,334
Foreign exchange losses 720,664
The capital tax was imposed under Swiss law and was
calculated by AG based on the amount of AG's assets less
liabilities.
The swap losses consist of the following items:
Amount in
Item U.S. Dollars
� swaps - periodic payments $1,652,436
Amortization � swap premium (95,087)
DM swaps - periodic payments 1,701,771
Total swap loss $3,259,120
The swap losses arose out of currency and interest rate exchange
agreements entered into by AG with third parties. Under these
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Last modified: May 25, 2011