Trinova Corporation and Subsidiaries - Page 6

                                        - 6 -                                         

                                                 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              





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