- 5 - issued to CMI-Texas 3,207,177 shares (i.e., 100 percent) of newly issued class B stock. On October 28, 1987, the market value of the debt interest was US$1,125,000, and the number of pesos the Mexican Government deposited into Industrias' account was computed based on the following formula: The face value of the debt (i.e., US$2,300,000) multiplied by the market foreign exchange rate for pesos (i.e., Mex$1639.94/US$), discounted by the authorized rate (i.e., 15 percent). On that day, the U.S.-dollar equivalent of the pesos deposited in the account was US$1,955,000. Industrias was required to use the pesos in the account to purchase goods and services provided by residents of Mexico. Prior to disbursement of the pesos, the Mexican Government required Industrias to make formal written requests, thus ensuring that the pesos would finance previously approved operations. In addition, Industrias' class B stock was subject to restrictions (i.e., CMI-Texas' rights to transfer, redeem, convert, and receive guaranteed dividends relating to, the stock were curtailed). On its consolidated Federal income tax return for the year ended May 31, 1988, petitioner did not report any gain relating to the swap transaction. Respondent determined that petitioner recognized a taxable gain of $830,000 (i.e., the amount realizedPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011