- 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
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