- 32 -
8. LIIBV transferred $18,985,000 to LIIBV Cura�ao.
9. LIIBV Cura�ao transferred $21,045,000 to LWSI.
10. LIIBV transferred $2,000,000 to LIL.
11. LIL transferred $2,000,000 to Transit and affiliates.
12. Transit and affiliates transferred $2,000,000 to LTL.
13. LTL repaid $2,000,000 in long-term debt.
14. LTI transferred $783,381 to Tree.
15. LWSI transferred $8,794,145 to LTI.
16. Transit transferred $981,987 to LTI.
August 31, 1988, Transfers
U.S. Subsidiaries to LIIBV and LIIBV Cura�ao
LIIBV and LIIBV Cura�ao to U.S. Subsidiaries
Transit $8,580,485 Transit -0-
LWSI 16,546,460 LWSI $22,000,000
Tree 581,666 Tree -0-
Total 25,708,611 Total 22,000,000
Steps for the August 31, 1988 Transfers
1. FNBC transferred $2,900,000 to LTI.
2. LTI received $19,617,722. Transit and LWSI transferred
funds to their respective general payables accounts with
FNBC. From these accounts, $19,617,722 was transferred to
LTI's FNBC master concentration account in an "Automatic
Clearing House" transaction.
3. LTI transferred $22,261,038 to LIIBV as follows: $6,688,667
on Transit's behalf and $15,572,371 on LWSI's behalf.
4. Tree transferred $581,666 to LIIBV.
5. Transit transferred $1,891,818 to LIIBV Cura�ao.
6. LWSI transferred $974,089 to LIIBV Cura�ao.
7. LIIBV transferred $19,134,704 to LIIBV Cura�ao.
8. LIIBV Cura�ao transferred $22,000,000 to LWSI.
9. LWSI transferred $22,000,000 to LTI.
10. LTI transferred $17,900,000 to LWSI.
11. LTI transferred $35,000,000 to LII.
12. LWSI transferred $40,993,136 to LTI.
13. LTI transferred $278,419 to Tree.
14. LTI transferred $6,651,824 to Transit.
c. LTL's Description of an LIIBV Transfer
In 1986, RBC arranged for LTL to borrow funds for what RBC
described as a "'double dip' taxation driven transaction". In
that transaction, RBC's loans were repaid in the United States
and new loans were made from Canada. LTL summarized the
following steps of one of those fund transfers in a memorandum
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