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million. Those 17 CDs comprised 263 “transferable individual
time deposit accounts” of $100,000 each. Each of those accounts
was insured by the Federal Deposit Insurance Corp.
MFE (Netherlands Antilles) N.V. (MFE N.V.), is a
Netherlands Antilles corporation. On January 28, 1993, MFE N.V.
purchased eight CDs from WFNNB in the total amount of $174.9
million (the MFE N.V. CDs). Each MFE N.V. CD was for a term of
1 year, showed an annual interest rate of 3.1 percent (annual
yield of 3.14 percent), and provided that it was a “non-
negotiable and
non-transferable time deposit”. Each also provided: “This Time
Deposit shall renew automatically for a like term unless and
until notice of withdrawal is presented at the Bank within * * *
seven calendar days after the maturity date”.
Reduction of Indebtedness to Limited Service
On January 28, 1993, WFNNB transferred the $174.9 million
received from MFE N.V. on the sale of the CDs to Limited Service
to reduce the balance outstanding under the line of credit
extended to WFNNB by Limited Service.
Petitioner’s Indirect Ownership of MFE N.V.
MFE N.V. is a fourth tier subsidiary of petitioner. The
relationship of MFE N.V. to petitioner, as well as the
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