H Group Holding, Inc. and Subsidiaries - Page 11




                                       - 100 -                                         

          consideration the adjustments for the allocation of fees, were               
          remitted to HHK and HS.30                                                    
               D.  Allocation to HIC for Management Services                           
               Beyond limited expense allocations, HIC’s subsidiaries did              
          not pay for services provided by HIC.  Respondent determined that            
          income should be allocated to HIC from its subsidiaries for                  
          management services.  Respondent relies on the provision of the              
          following services in support of allocations:  Manuals, training,            
          human resource development, employee benefits, contract review,              
          financial systems and advice, business development assistance,               
          preopening services, owner relations, marketing, and HIC's                   
          efforts at building the IMAGE reservations system.                           
               Petitioners contend that, for the most part, all management             
          fees were reported by the entity that earned them.  Petitioners              
          also argue that what HIC did for its subsidiaries was stewardship            
          or duplication and as such is not subject to section 482                     
          allocations.  Petitioners assert that the design and chain                   
          services were provided to and paid for separately by the hotel               
          owners, not the subsidiaries, and thus were by definition arm’s-             
          length transactions not subject to section 482.  Petitioners also            


               30  This allocation is for the Hyatt trade names and marks.             
          We consider the other items proposed by respondent, through his              
          expert BVS, in the royalty--i.e., corporate overhead and                     
          development activities--under the topic of management services,              
          below.                                                                       





Page:  Previous  90  91  92  93  94  95  96  97  98  99  100  101  102  103  104  105  106  107  108  109  Next

Last modified: May 25, 2011