General Motors Corporation and Subsidiaries - Page 53




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          item (the rate support payment) was not an expense (deduction)               
          for one member of the group (GM) and income for another member               
          (GMAC).  The payment GM made to GMAC (which was the deduction)               
          was not directly related to the payments the retail/fleet                    
          customers made to GMAC (which contained the discount income).                
               Additionally, here the money left the consolidated group.               
          Compare the examples of rate supported and nonrate-supported                 
          RISC's bearing a below-market rate of interest.  See supra pp.               
          33-36.  In the example of a nonrate-supported RISC bearing a                 
          below-market rate of interest, GMAC paid the independent GM                  
          dealer $9,500.  Thus, the GM group's total net expense was                   
          $9,500.  In the example of a rate-supported RISC, GMAC paid the              
          independent GM dealer $10,000 and GM paid GMAC $500.  Thus, the              
          GM group's total net expense was $10,000.  Five hundred dollars              
          ($500) more left the GM group when a below-market RISC/fleet loan            
          was rate supported as compared with when there was no rate                   
          support.                                                                     
               As respondent pointed out on brief, the matching rule                   
          ensures clear reflection of income and prevents the creation of              
          "paper" deductions when the group as a whole has not incurred a              
          net expense.  Here, the group had a net expense.                             
               Furthermore, the GM group's additional $500 expense was a               
          real loss of $500 to the GM group.  In both the example of a                 
          nonrate-supported RISC and a rate-supported RISC bearing a below-            





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