- 48 - Revenue Code section 482 and Treasury regulation section 1.482(d), it is determined that an arm’s-length charge for management services performed by Hyatt-Hong Kong, Hyatt-Singapore and Hyatt-Panama equals $73,200.00 per hotel managed in 1976 through 1978. * * * The management fees adjustments generally represent all of the net income of the named subsidiaries in excess of respondent’s determined per-hotel allowance, less the amount already determined as trade name royalty. The February 28, 1995, notice for AIC’s 1979 through 1983 taxable years contained the same explanations for these adjustments as the November 18, 1994, notice, except that the per-hotel arm’s-length charges determined by respondent were as follows: Year Amount 1979 $75,000 1980 87,500 1981 100,000 1982 62,000 1983 62,000 The number of hotels respondent used to compute the fee adjustments were as follows: Year HHK HS HP 1976 6 2 1 1977 6 2 1 1978 7 2 1 1979 9 3 1 1980 20 3 1 1981 28 2 1 1982 14 2 1 1983 17 2 1Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
Last modified: May 25, 2011